https://www.taxtmi.com/caselaws?id=365378 Interest paid by an Indian branch of a foreign bank to its overseas head office was treated as deductible in computing the income of the Indian permanent establishment, because the India-Japan treaty protocol to Article 7(3) allowed deduction of interest on funds advanced in the course of banking business and the payment was not treated as a payment to self. The corresponding interest received by the head office from the Indian branch was held not chargeable to tax in India under the domestic law and treaty position followed by the Tribunal. The notice objection under section 163 was treated as ancillary and did not affect the substantive relief. en-us Mon, 13 Aug 2018 00:00:00 +0530 Thu, 16 Aug 2018 07:57:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365378 Interest paid by an Indian branch of a foreign bank to its overseas head office was treated as deductible in computing the income of the Indian permanent establishment, because the India-Japan treaty protocol to Article 7(3) allowed deduction of interest on funds advanced in the course of banking business and the payment was not treated as a payment to self. The corresponding interest received by the head office from the Indian branch was held not chargeable to tax in India under the domestic law and treaty position followed by the Tribunal. The notice objection under section 163 was treated as ancillary and did not affect the substantive relief. Case-Laws Income Tax Mon, 13 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365378