https://www.taxtmi.com/caselaws?id=390406 Revision under section 263 is not sustainable where the Assessing Officer, after enquiry, adopts a possible view on a debatable issue. The text notes that interest paid by an Indian branch to its head office and overseas branches was treated as not taxable in India on the basis of Special Bench reasoning, including the mutuality concept and the view that beneficial treaty provisions may prevail over the Act. It also states that Explanation (a) to section 9(1)(v)(c), inserted by the Finance Act, 2015, applies prospectively from 1 April 2016 and cannot be used to disturb earlier assessments made under the law then in force. en-us Mon, 30 Dec 2019 00:00:00 +0530 Wed, 01 Jan 2020 18:01:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390406 Revision under section 263 is not sustainable where the Assessing Officer, after enquiry, adopts a possible view on a debatable issue. The text notes that interest paid by an Indian branch to its head office and overseas branches was treated as not taxable in India on the basis of Special Bench reasoning, including the mutuality concept and the view that beneficial treaty provisions may prevail over the Act. It also states that Explanation (a) to section 9(1)(v)(c), inserted by the Finance Act, 2015, applies prospectively from 1 April 2016 and cannot be used to disturb earlier assessments made under the law then in force. Case-Laws Income Tax Mon, 30 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390406