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Taxing the interest on income tax refund received u/s 244A - Non-Resident (Foreign Company) - since the assessee is benefitted with the protocol to the India-Netherland treaty dated 21.01.1989 and the favorable provisions of India-Italy tax treaty are applicable on the assessee company because Netherland and Italy both are members of the Organization for Economic Cooperation and Development (OECD) - Amount not taxable - AT