Interest income on income tax refund chargeable @10% as per India-Japan tax treaty

MUFG Bank Ltd. Vs ACIT (ITAT Delhi)

ITAT Delhi held that interest income on income tax refund is chargeable at the rate of 10% as per Article 11 of India – Japan tax treaty.

Facts- The assessee, a banking company, is a tax resident of Japan. In the return of income so filed, the assessee offered to tax interest on Income Tax refund amounting to Rs.6,83,72,179/- at the rate of 10% under Article 11(2) of India Japan Double Taxation Avoidance Agreement (DTAA).

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