Interest on Income-tax Refund Taxable at DTAA Rate When No PE in Year of Receipt: ITAT Dehradun

R And B Falcon A Pvt Ltd Vs ACIT (ITAT Dehradun) Interest on Income-tax Refund Taxable at DTAA Rate When No PE in Year of Receipt: ITAT Dehradun Allows Treaty Benefit to Australian Company The Dehradun Bench of the Income Tax Appellate Tribunal, Dehradun Bench allowed the appeal of R & B Falcon A Pty Ltd. (Australia) for AY 2022-23, holding that interest on income-tax refund of ₹2.02 crore is taxable at 15% under Article 11 of the India–Australia DTAA, and not as business income at normal rates. The assessee had received interest u/s 244A during AY 2022-23 relating to refunds for AYs 2...