https://www.taxtmi.com/highlights?id=55786 Income accrued in India - interest income and commitment fees earned by DZ Bank from its Indian clients - PE in India - Once entire interest revenues earned in India in the hands of the foreign enterprise is taxed in its hands under article 11- as is the undisputed position in this case, nothing survives for taxation under article 7, and, given the fact that entire related revenues are taxed in the hands of the assessee on gross basis under article 11, directly or indirectly, nothing more than entire business receipts can be brought to tax in India. - AT en-us Mon, 07 Dec 2020 10:55:17 +0530 Mon, 07 Dec 2020 10:55:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=55786 Income accrued in India - interest income and commitment fees earned by DZ Bank from its Indian clients - PE in India - Once entire interest revenues earned in India in the hands of the foreign enterprise is taxed in its hands under article 11- as is the undisputed position in this case, nothing survives for taxation under article 7, and, given the fact that entire related revenues are taxed in the hands of the assessee on gross basis under article 11, directly or indirectly, nothing more than entire business receipts can be brought to tax in India. - AT Highlights Income Tax Mon, 07 Dec 2020 10:55:17 +0530 https://www.taxtmi.com/highlights?id=55786