Case Law Details
Case Name : Transocean Offshore International Ventures Ltd. Vs DCIT (ITAT Delhi)
Related Assessment Year : 2012-13
Courts :
All ITAT ITAT Delhi
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Transocean Offshore International Ventures Ltd. Vs DCIT (ITAT Delhi)
Gist of the pronouncement – Interest on income tax refund received by the non-resident companies shall be taxable as per the provision of Tax Treaty irrespective of the fact that whether the assessee has PE in India or not.
Assessee’s Stand – Assessee company offered the interest on income tax refund as per the beneficial provision of Article 11 of the India USA Tax Treaty (i.
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