Disputed tax under DTVSV Act doesn’t include interest granted u/s 244A of IT Act

Cooperative Rabobank U A Vs CIT  (Bombay High Court) Facts- A return of income was filed declaring Nil income. However, an Assessment Order assessing business profits attributable to permanent establishment (PE) at Rs.1,50,75,790/- was passed. CIT(A) passed an order holding that Petitioner does not have PE in India and deleted the addition made by the AO. The order giving effect to the CIT(A) order was passed pursuant to which a sum of Rs.7,75,272/- was interest under Section 244A of the IT Act on the refund due to the Petitioner. The main cause of the writ petition is that the petitioner is ...