https://www.taxtmi.com/caselaws?id=768560 Interest on supplier credit and related trade finance receipts remained taxable at the treaty rate under Article 11(2) of the India-Japan DTAA because the Revenue did not prove effective connection with the Indian permanent establishment. Article 11(6) displaces the concessional interest article only where the debt-claim is directly or indirectly attributable to the permanent establishment or fixed base; mere existence of a permanent establishment is insufficient. On the record, no cogent material showed that the permanent establishment played any role in earning the interest, so business-income taxation under Article 7 was not warranted and the treaty-rate treatment was upheld. en-us Wed, 19 Mar 2025 00:00:00 +0530 Wed, 09 Apr 2025 07:42:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768560 Interest on supplier credit and related trade finance receipts remained taxable at the treaty rate under Article 11(2) of the India-Japan DTAA because the Revenue did not prove effective connection with the Indian permanent establishment. Article 11(6) displaces the concessional interest article only where the debt-claim is directly or indirectly attributable to the permanent establishment or fixed base; mere existence of a permanent establishment is insufficient. On the record, no cogent material showed that the permanent establishment played any role in earning the interest, so business-income taxation under Article 7 was not warranted and the treaty-rate treatment was upheld. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768560