https://www.taxtmi.com/caselaws?id=466747 Interest paid by an Indian branch to its head office and overseas branches was treated as a payment to self and, under the mutuality principle, was not taxable in India for the relevant years. The Tribunal also held that the Explanation inserted in section 9(1)(v)(c) by the Finance Act, 2015 operated prospectively from assessment year 2016-17 and could not be used to treat the completed assessment for assessment year 2013-14 as erroneous. As the Assessing Officer had followed the consistent view taken in earlier years and the assessee's disclosures, the allegation of lack of inquiry failed and the conditions for revision under section 263 were not satisfied. en-us Fri, 26 Aug 2022 00:00:00 +0530 Wed, 18 Feb 2026 20:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466747 Interest paid by an Indian branch to its head office and overseas branches was treated as a payment to self and, under the mutuality principle, was not taxable in India for the relevant years. The Tribunal also held that the Explanation inserted in section 9(1)(v)(c) by the Finance Act, 2015 operated prospectively from assessment year 2016-17 and could not be used to treat the completed assessment for assessment year 2013-14 as erroneous. As the Assessing Officer had followed the consistent view taken in earlier years and the assessee's disclosures, the allegation of lack of inquiry failed and the conditions for revision under section 263 were not satisfied. Case-Laws Income Tax Fri, 26 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466747