https://www.taxtmi.com/caselaws?id=754066 ITAT Mumbai dismissed assessee's challenge to NaFAC's notice u/s 143(2), holding it valid under the Act. The Tribunal rejected the assessee's claim for domestic company tax rates under India-France Tax Treaty Article 26, following Supreme Court precedent in J.K. Synthetics. Regarding data processing fees to Singapore branch, ITAT ruled in assessee's favor, holding Article 13 inapplicable. For interest payments between Indian branches and overseas head office, Tribunal applied Article 12(5) read with Article 7 of DTAA, concluding such interest is non-taxable at head office level since branches constitute permanent establishments. The rental income addition issue was remanded to assessing officer for fresh consideration after proper verification. en-us Mon, 13 May 2024 00:00:00 +0530 Sat, 15 Jun 2024 12:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754066 ITAT Mumbai dismissed assessee's challenge to NaFAC's notice u/s 143(2), holding it valid under the Act. The Tribunal rejected the assessee's claim for domestic company tax rates under India-France Tax Treaty Article 26, following Supreme Court precedent in J.K. Synthetics. Regarding data processing fees to Singapore branch, ITAT ruled in assessee's favor, holding Article 13 inapplicable. For interest payments between Indian branches and overseas head office, Tribunal applied Article 12(5) read with Article 7 of DTAA, concluding such interest is non-taxable at head office level since branches constitute permanent establishments. The rental income addition issue was remanded to assessing officer for fresh consideration after proper verification. Case-Laws Income Tax Mon, 13 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754066