https://www.taxtmi.com/caselaws?id=774840 Compensation and interest received under an arbitral award were treated as business income because they arose from non-payment of dues for offshore supplies and remained inseparably linked to the underlying commercial arrangement. The award merely crystallised amounts already payable under the contract, and the interest component was incidental to the same business receipt rather than a separate source of income. In the absence of a permanent establishment in India, Article 7 of the India-Japan DTAA applied, with the result that the receipts were not taxable in India. en-us Tue, 08 Jul 2025 00:00:00 +0530 Tue, 12 Aug 2025 12:16:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774840 Compensation and interest received under an arbitral award were treated as business income because they arose from non-payment of dues for offshore supplies and remained inseparably linked to the underlying commercial arrangement. The award merely crystallised amounts already payable under the contract, and the interest component was incidental to the same business receipt rather than a separate source of income. In the absence of a permanent establishment in India, Article 7 of the India-Japan DTAA applied, with the result that the receipts were not taxable in India. Case-Laws Income Tax Tue, 08 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774840