https://www.taxtmi.com/caselaws?id=786653 Interest on an income-tax refund received by a non-resident is taxable under the DTAA interest article, not as business profits, unless the income is effectively connected with a permanent establishment in India in the year of receipt. A historical permanent establishment in earlier assessment years is not enough to displace the treaty treatment where no permanent establishment exists when the refund interest accrues. On that basis, the treaty-rate treatment under the interest article applied to the refund interest, and business-profits taxation was rejected. en-us Fri, 30 Jan 2026 00:00:00 +0530 Tue, 17 Feb 2026 07:29:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786653 Interest on an income-tax refund received by a non-resident is taxable under the DTAA interest article, not as business profits, unless the income is effectively connected with a permanent establishment in India in the year of receipt. A historical permanent establishment in earlier assessment years is not enough to displace the treaty treatment where no permanent establishment exists when the refund interest accrues. On that basis, the treaty-rate treatment under the interest article applied to the refund interest, and business-profits taxation was rejected. Case-Laws Income Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786653