Allowing the appeal the Tribunal held that,  revision cannot be initiated on the basis of  retrospective amendment as the AO has to  proceed on the basis of law prevailing as on the date of assessments. Revision is held to be not valid. whether or not interest received by the Head Office/overseas Branches from the Indian Branch is taxable in India is a highly debatable issue and the position of law prevailing at the time of completion of assessments as per the available judicial precedents on the issue, clearly held that the interest income was not taxable as it is governed by the principle of mutuality. Therefore, it cannot be said that it is not a possible view.(AY. 2011-12, 2012-13)