244A\n(Rs.46,69,244).\n\n5. On the facts and in the circumstances of the case and in law, the Hon'ble\nCIT(A) erred in upholding the levy of tax @41.6% on interest on income tax\nrefund considering the same to be attributable to alleged PE in India without\nappreciating that the same is taxable @ 15% in terms