Introducing the “In Favour Of” filter in Case Laws.
- ⚖️ Instantly identify judgments decided in favour of the Assessee, Revenue, or Appellant
- 🔍 Narrow down results with higher precision
Try it now in Case Laws →
TaxTMI Login
🚀 New Feature Launched ✕
Just a moment...
Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Highlights
of of All Highlights
Note
Bookmark
Share
Don't have an account? Register Here
of Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee has received interest income are also the clients of the assessee in India with whom contracts were executed through the Permanent Establishment in India and the assessee has received fees for technical services in a previous year from them, but then the performance of contracts through the PE or receipt of fees for technical services from such clients is irrelevant as long as the interest income is not demonstrated to be attributable to the permanent establishment. Such an attribution cannot be inferred or assumed - AT
TaxTMI 
TaxTMI 
