https://www.taxtmi.com/caselaws?id=283297 Interest received by overseas branches on external commercial borrowings extended to Indian borrowers was treated as not attributable to the Indian branches under the treaty claim, but the Tribunal followed its earlier decision in the assessee's own case and decided the issue against the assessee. Interest under section 234D was held chargeable only up to the date of the original regular assessment, because regular assessment means the first assessment under section 143(3) or 144 and not a later consequential or remand order. The challenge on this point was therefore accepted in part, limiting the charging period to the original assessment. en-us Tue, 27 Feb 2018 00:00:00 +0530 Wed, 18 Sep 2019 09:51:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=283297 Interest received by overseas branches on external commercial borrowings extended to Indian borrowers was treated as not attributable to the Indian branches under the treaty claim, but the Tribunal followed its earlier decision in the assessee's own case and decided the issue against the assessee. Interest under section 234D was held chargeable only up to the date of the original regular assessment, because regular assessment means the first assessment under section 143(3) or 144 and not a later consequential or remand order. The challenge on this point was therefore accepted in part, limiting the charging period to the original assessment. Case-Laws Income Tax Tue, 27 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=283297