https://www.taxtmi.com/caselaws?id=219390 Interest paid by an Indian branch of a foreign bank to its head office was treated as a payment to self under domestic law, but it remained deductible in computing profits attributable to the permanent establishment under the relevant treaty, and was not taxable in India in the foreign enterprise's hands. On that basis, the interest disallowance was deleted. A separately raised ground on the taxability of the corresponding interest income in the head office's hands was admitted as arising from the record, but was remanded to the first appellate authority for fresh adjudication after hearing the assessee. en-us Wed, 25 Jul 2012 00:00:00 +0530 Wed, 03 Oct 2012 18:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219390 Interest paid by an Indian branch of a foreign bank to its head office was treated as a payment to self under domestic law, but it remained deductible in computing profits attributable to the permanent establishment under the relevant treaty, and was not taxable in India in the foreign enterprise's hands. On that basis, the interest disallowance was deleted. A separately raised ground on the taxability of the corresponding interest income in the head office's hands was admitted as arising from the record, but was remanded to the first appellate authority for fresh adjudication after hearing the assessee. Case-Laws Income Tax Wed, 25 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219390