Assessee an Indian Branch of Bank in Netherlands, had an undisclosed TDS credit.  Assessee submitted that difference in income appearing in Form 26AS vis-a-vis Profit & Loss Account and return of income could be brought to tax representing interest on external commercial borrowing in hands of assessee at tax rates prescribed under article 11. Assessing Officer brought to tax difference of undisclosed gross receipts as per Form 26AS and return of income as normal business receipts taxable at rate of 40 per cent as applicable to a foreign company instead of applying tax rate provided in article 11. CIT(A) deleted the addition. On appeal the Tribunal held that  since nature of income that was sought to be taxed was interest income, in view of article 11(2), Assessing Officer should bring to tax interest income at rate of 10 per cent. Appeal of Revenue is dismissed. (AY. 2012-13)