https://www.taxtmi.com/caselaws?id=216557 Interest on income-tax refund received by a permanent establishment in India was held not to be effectively connected with the PE's business operations, because it arose only from excess tax payment and delayed refund rather than from the underlying contract activity. The receipt was therefore treated as a separate treaty-covered item under the DTAA's specific interest article and not as business income under domestic law. Accordingly, the treaty rate applied and the Revenue's attempt to tax it under the domestic law route failed. en-us Mon, 30 Jul 2012 00:00:00 +0530 Tue, 11 Sep 2012 11:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216557 Interest on income-tax refund received by a permanent establishment in India was held not to be effectively connected with the PE's business operations, because it arose only from excess tax payment and delayed refund rather than from the underlying contract activity. The receipt was therefore treated as a separate treaty-covered item under the DTAA's specific interest article and not as business income under domestic law. Accordingly, the treaty rate applied and the Revenue's attempt to tax it under the domestic law route failed. Case-Laws Income Tax Mon, 30 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216557