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In favour of assessee.The assessee has challenged the addition on account of interest received on External Commercial Borrowings [ECB], extended to Indian borrowers.

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Section 234D of the Income Tax Act, 1961 — Interest — Refund — No interest was leviable under section 234D as amount of refund granted to assesee for earlier period was adjusted against outstanding demand for the relevant year — Bank of Tokyo Mitsubishi UFJ Ltd. vs. Deputy Commissioner of income tax [2020] 180 ITD 300(Delhi-trib)

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