Assessee, company incorporated in Luxemborg, subscribed to NCDs floated by GIPL, Indian company-Assessee offered interest income received from said NCDs to tax under section 194LD.  Assessment orders were framed accepting income derived from aforesaid NCDs in terms of section 194LD-Thereafter, Assessing Officer issued notice under section 148A(b) on ground that interest income had not been appropriately offered to tax on account of mischaracterization of income. Thereafter, order under section 148A(d) was passed wherein principal allegation was that although funds were taken out in form of interest payments, they were in fact liable to be declared as dividend and subjected to DDT in terms of section 115-O. On writ the Court held that since assessee was merely recipient of interest income and it was thus, clearly not entity which had either declared or paid dividend, even if payment were to be assumed to be dividend, liability to pay tax thereon could have only been foisted upon company which had declared, distributed or paid same and in facts of present case it would have been GIPL. Therefore,  order and consequential reopening notices are  quashed(AY. 2018-19)