https://www.taxtmi.com/caselaws?id=327964 Interest paid under Section 244-A on income-tax refunds was treated as a debt-claim because the entitlement arises only when the refund becomes due and payable. On that footing, the court read the term "interest" in Article 12(4) of the India-Italy DTAA broadly enough to cover such refund interest, bringing it within the exemption in Article 12(3)(a) where the Government is the payer. Article 12(6) was held inapplicable because it addresses a different situation involving interest borne by a permanent establishment. The tax deduction on refund interest was therefore unsustainable. en-us Wed, 20 Apr 2016 00:00:00 +0530 Sat, 18 Jun 2016 10:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327964 Interest paid under Section 244-A on income-tax refunds was treated as a debt-claim because the entitlement arises only when the refund becomes due and payable. On that footing, the court read the term "interest" in Article 12(4) of the India-Italy DTAA broadly enough to cover such refund interest, bringing it within the exemption in Article 12(3)(a) where the Government is the payer. Article 12(6) was held inapplicable because it addresses a different situation involving interest borne by a permanent establishment. The tax deduction on refund interest was therefore unsustainable. Case-Laws Income Tax Wed, 20 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327964