https://www.taxtmi.com/caselaws?id=178111 Rectification under section 154 was treated as valid where the lower tax rate on interest income had been allowed without conscious examination in the original assessment, so the challenge failed. Interest on bank deposits was held attributable to the permanent establishment and taxable at the normal rate, following the assessee's own earlier-year position. Interest on income-tax refund was held eligible for concessional treaty taxation under co-ordinate bench reasoning. The component relating to delayed payment on a foreign supply contract was not decided by the first appellate authority and was restored to the assessing authority for fresh adjudication after hearing the assessee. en-us Wed, 11 Dec 2013 00:00:00 +0530 Fri, 14 Oct 2016 12:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178111 Rectification under section 154 was treated as valid where the lower tax rate on interest income had been allowed without conscious examination in the original assessment, so the challenge failed. Interest on bank deposits was held attributable to the permanent establishment and taxable at the normal rate, following the assessee's own earlier-year position. Interest on income-tax refund was held eligible for concessional treaty taxation under co-ordinate bench reasoning. The component relating to delayed payment on a foreign supply contract was not decided by the first appellate authority and was restored to the assessing authority for fresh adjudication after hearing the assessee. Case-Laws Income Tax Wed, 11 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178111