https://www.taxtmi.com/caselaws?id=753352 Interest received by an Indian permanent establishment from its head office and overseas branches was treated as taxable in India. The applicable treaty framework, including Article 7(3) of the India-US Double Taxation Avoidance Agreement, was applied as a special rule for banking enterprises, and the branch and head office were regarded as one legal person, making the receipt a transaction with self. The later domestic fiction in the Explanation to Section 9(1)(v) of the Income-tax Act, 1961, was noted as not applicable for the relevant assessment year, but it did not alter the result. en-us Tue, 28 May 2024 00:00:00 +0530 Thu, 30 May 2024 11:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753352 Interest received by an Indian permanent establishment from its head office and overseas branches was treated as taxable in India. The applicable treaty framework, including Article 7(3) of the India-US Double Taxation Avoidance Agreement, was applied as a special rule for banking enterprises, and the branch and head office were regarded as one legal person, making the receipt a transaction with self. The later domestic fiction in the Explanation to Section 9(1)(v) of the Income-tax Act, 1961, was noted as not applicable for the relevant assessment year, but it did not alter the result. Case-Laws Income Tax Tue, 28 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753352