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2018 (8) TMI 854 - AT - Income TaxReopening of assessment - Taxability of deemed interest income on deposits - DTAA between India and Singapore - it is claimed that, operations of the said banking company had been wound up in December 2003 - further, the amount on which interest was earned was in the nature of a fixed deposit and not a loan prescribed as per Article 11(2)(a) of the India-Singapore DTAA . Held that:- once the reopening has been held to be invalid and the revenue chooses not to challenge the same, the adjudication on merits is a purposeless reason. Hence, this appeal filed by the Revenue is dismissed. - Decided against the revenue.
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