S. 195 TDS provisions applies only when remittance results in taxable income

Barclays Bank PLC Vs ADIT (ITAT Mumbai) Second ground of appeal is about disallowance of interest paid to the head office (HO)/overseas branches on deposits placed with the assessee under section 40(a)(i) of the Act. During the assessment proceedings, the assessing officer found that the assessee had paid interest of Rs. 2.99 crores to the HO/overseas branches (OBs) on deposit placed with it by those entities, that it had debited the interest payment to the P & L account for the year under appeal, that it had claimed a deduction in respect of the same. On being queried as to whether tax wa...