TDS on interest paid by assessee Indian branch of a Belgian bank to its head Office

Interest was paid by assessee Indian branch of a Belgian bank to its head Office on subordinate debts and term borrowing. HELD, in view of domestic law as well as treaty same would not be chargeable to tax in India and thus, TDS provision of section 195 would not be attracted and, hence, question of disallowance under section 40(a)(i) did not arise. Next ground of appeal is about disallowance of interest paid by the assessee to HO amounting to Rs.8.57Crores.During the assessment proceedings, AO found that interest of Rs.8,56,15, 525/- was paid by the assessee to HO on subordinate debts and ter...