The Bangalore Income Tax Appellate Tribunal (ITAT) recently issued two related orders regarding the payment of interest on the refund of tax withheld in error under the 1989 tax treaty with the United States. The cases involved an Indian company, Infosys BPO Ltd., which is engaged in the business of providing business process outsourcing services. In 2015, Infosys made a series of payments to two different companies in the United States, which were marked as in the nature of training fees. The payments were made after grossing up the invoice amount and tax deducted at source (TDS). The payment of...