https://www.taxtmi.com/caselaws?id=61909 The India-Malta tax treaty became operative in India only for income of the fiscal year beginning on or after 1 April 1996, because its Indian effectiveness was tied to the year following actual entry into force on 22-12-1995; treaty relief was therefore not available for assessment year 1996-97. A return filed under section 172(7) was treated as an optional refund claim return, and interest under section 234A was not attracted on that basis. The result was that treaty relief failed for the earlier year, while the levy of interest under section 234A on the special return was not sustained. en-us Thu, 22 Apr 1999 00:00:00 +0530 Mon, 17 Jan 2011 09:51:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61909 The India-Malta tax treaty became operative in India only for income of the fiscal year beginning on or after 1 April 1996, because its Indian effectiveness was tied to the year following actual entry into force on 22-12-1995; treaty relief was therefore not available for assessment year 1996-97. A return filed under section 172(7) was treated as an optional refund claim return, and interest under section 234A was not attracted on that basis. The result was that treaty relief failed for the earlier year, while the levy of interest under section 234A on the special return was not sustained. Case-Laws Income Tax Thu, 22 Apr 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61909