https://www.taxtmi.com/caselaws?id=292059 The ITAT dismissed the Revenue's appeal in all four issues. It held that Data Processing Cost is not 'Royalty' but a reimbursement of expenses, interest paid by the branch to its Head Office is allowable, disallowance under Section 14A does not apply without exempt income, and interest income on Income Tax refund is taxed at 15% under the DTAA. The decisions were based on legal interpretations and precedents set by previous Co-ordinate Bench rulings. en-us Thu, 31 Jan 2019 00:00:00 +0530 Sat, 05 Dec 2020 12:13:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=292059 The ITAT dismissed the Revenue's appeal in all four issues. It held that Data Processing Cost is not 'Royalty' but a reimbursement of expenses, interest paid by the branch to its Head Office is allowable, disallowance under Section 14A does not apply without exempt income, and interest income on Income Tax refund is taxed at 15% under the DTAA. The decisions were based on legal interpretations and precedents set by previous Co-ordinate Bench rulings. Case-Laws Income Tax Thu, 31 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=292059