https://www.taxtmi.com/caselaws?id=383380 A payment by an Indian branch to its head office was treated as a payment to self, so the principle of mutuality prevented tax on data processing fee and interest for the relevant assessment year; the later amendment to section 9(1)(v)(c) was held inapplicable retrospectively. By contrast, the claim to the tax rate applicable to domestic companies and co-operative banks under Article 26 of the India-France DTAA was rejected because the issue had already been consistently decided against the assessee on the same facts. The cross appeals were disposed of issue-wise on that basis. en-us Wed, 17 Jul 2019 00:00:00 +0530 Mon, 22 Jul 2019 16:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383380 A payment by an Indian branch to its head office was treated as a payment to self, so the principle of mutuality prevented tax on data processing fee and interest for the relevant assessment year; the later amendment to section 9(1)(v)(c) was held inapplicable retrospectively. By contrast, the claim to the tax rate applicable to domestic companies and co-operative banks under Article 26 of the India-France DTAA was rejected because the issue had already been consistently decided against the assessee on the same facts. The cross appeals were disposed of issue-wise on that basis. Case-Laws Income Tax Wed, 17 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383380