Australia DTAA: Whether Interest on Refund Taxable under Article XI ?

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The assessee was a non-resident company having a permanent establishment in India. The assessee earned various income mainly from the contract with ONGC, ‘C’ Ltd. and ‘N’ Ltd. One of the income declared by the assessee-company was interest on income-tax refund which it claimed taxable @ 15 % on gross basis in view of the…