https://www.taxtmi.com/caselaws?id=176849 The appeal was allowed by the Tribunal, ruling that the interest on income tax refund was not effectively connected with the Permanent Establishment (PE) based on the asset-test and activity-test. As a result, the interest was held to be taxable under a specific article of the treaty, and the appellant succeeded on this ground. The decision was pronounced on September 21, 2011, with the other issues not being adjudicated. en-us Wed, 21 Sep 2011 00:00:00 +0530 Tue, 10 Oct 2017 09:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176849 The appeal was allowed by the Tribunal, ruling that the interest on income tax refund was not effectively connected with the Permanent Establishment (PE) based on the asset-test and activity-test. As a result, the interest was held to be taxable under a specific article of the treaty, and the appellant succeeded on this ground. The decision was pronounced on September 21, 2011, with the other issues not being adjudicated. Case-Laws Income Tax Wed, 21 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176849