https://www.taxtmi.com/caselaws?id=271637 ITAT Mumbai allowed the assessee's appeal and held that no tax was required to be deducted at source under section 195 on interest payments made by the Indian branch of a foreign bank to its overseas head office, as such payments are effectively made by a non-resident to itself. Consequently, the disallowance made through rectification under section 154 was unsustainable, and the CIT(A) erred in upholding it. ITAT further held that denial of interest under section 244A for a specified period could not be treated as a mistake apparent from the record, since only the Commissioner/Chief Commissioner can determine the excludable period. en-us Fri, 08 Jan 2016 00:00:00 +0530 Sat, 22 Nov 2025 13:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271637 ITAT Mumbai allowed the assessee's appeal and held that no tax was required to be deducted at source under section 195 on interest payments made by the Indian branch of a foreign bank to its overseas head office, as such payments are effectively made by a non-resident to itself. Consequently, the disallowance made through rectification under section 154 was unsustainable, and the CIT(A) erred in upholding it. ITAT further held that denial of interest under section 244A for a specified period could not be treated as a mistake apparent from the record, since only the Commissioner/Chief Commissioner can determine the excludable period. Case-Laws Income Tax Fri, 08 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271637