https://www.taxtmi.com/highlights?id=87274 ITAT held that mere presence of PE in India does not automatically disqualify special tax treatment under Article 11(2) of India-Japan DTAA for interest income from supplier's credit. No evidence demonstrated direct attribution of interest income to Indian PE, thus preserving taxpayer's entitlement to preferential tax rate. Revenue's contention rejected, with tribunal finding no distinguishing circumstances from prior assessments. Interest income remains taxable at special rates, affirming taxpayer's original tax treatment and interpretation of bilateral tax agreement provisions. en-us Wed, 09 Apr 2025 07:42:31 +0530 Wed, 09 Apr 2025 07:42:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=87274 ITAT held that mere presence of PE in India does not automatically disqualify special tax treatment under Article 11(2) of India-Japan DTAA for interest income from supplier's credit. No evidence demonstrated direct attribution of interest income to Indian PE, thus preserving taxpayer's entitlement to preferential tax rate. Revenue's contention rejected, with tribunal finding no distinguishing circumstances from prior assessments. Interest income remains taxable at special rates, affirming taxpayer's original tax treatment and interpretation of bilateral tax agreement provisions. Highlights Income Tax Wed, 09 Apr 2025 07:42:31 +0530 https://www.taxtmi.com/highlights?id=87274