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ITAT held that mere presence of PE in India does not automatically disqualify special tax treatment under Article 11(2) of India-Japan DTAA for interest income from supplier's credit. No evidence demonstrated direct attribution of interest income to Indian PE, thus preserving taxpayer's entitlement to preferential tax rate. Revenue's contention rejected, with tribunal finding no distinguishing circumstances from prior assessments. Interest income remains taxable at special rates, affirming taxpayer's original tax treatment and interpretation of bilateral tax agreement provisions.
ITAT held that mere presence of PE in India does not automatically disqualify special tax treatment under Article 11(2) of India-Japan DTAA for interest income from supplier's credit. No evidence demonstrated direct attribution of interest income to Indian PE, thus preserving taxpayer's entitlement to preferential tax rate. Revenue's contention rejected, with tribunal finding no distinguishing circumstances from prior assessments. Interest income remains taxable at special rates, affirming taxpayer's original tax treatment and interpretation of bilateral tax agreement provisions.
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