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). While framing the final assessment order in pursuance to the directions of learned DRP, AO taxed the interest on Income Tax refund by ap...