2020 (3) TMI 1475

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.... For the Respondent : Shri S. Ramakrishnan, CIT ORDER PER N.R.S. GANESAN, JUDICIAL MEMBER:  This appeal of the assessee is directed against the assessment order consequent to the direction of the Dispute Resolution Panel dated 31.08.2016. 2. Shri Sriram Seshadri, the Ld. Representative for the assessee submitted that he was instructed to not press the Ground Nos.1,2,3,4 & 6 raise....

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.... levied only on the basis of the LIBOR and not under PLR. The Ld. Representative for the assessee very fairly submitted that he is not disputing the charging of interest on the delayed receipt of money from non-residents. 4. On the contrary, Shri S. Ramakrishnan, the Ld. Departmental Representative submitted that the source of funds on which the interest was charged is from India. Therefore the....

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....f the above, we are unable to uphold the orders of the authorities below. Accordingly, the orders of authorities below are set aside and the Assessing Officer is directed to charge interest under LIBOR rate. 6. The next issue arises for consideration is disallowance of amount reimbursed to M/s. GTE Overseas Corporation for nondeduction of tax. 7. Shri Sriram Seshadri, the Ld. Representative ....

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....cumstances, the Ld. Representative submitted that the matter be kept pending till the AAR decide the issue one way or the other. The Ld. Representative further submitted that in the earlier assessment year, this Tribunal has remitted back the matter to the file of the Assessing Officer for reconsideration with a direction to decide the issue after the decision of the AAR. The Ld. Representative ha....