In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue
Bench: Us.
115C of the I.T. Act and tax should have been charged @20%. This provision of the act has not been correctly interpreted and has been wrongly ignored for assessment. 9. That, without prejudice, the provisions of Double Taxation Avoidance Agreement between India and U.K. has been wrongly interpreted. Even on the basis of stated facts and observations made