https://www.taxtmi.com/caselaws?id=469862 Where the Indian associated enterprise has already been remunerated at arm's length for the covered transactions, no further profit attribution is warranted to the foreign enterprise merely on the basis of an alleged business connection or dependent agent permanent establishment in India. Interest on income-tax refund is not effectively connected with the permanent establishment on either an asset test or an activity test, so Article 7 does not exclude it and the treaty provision on interest income applies. The commentary therefore states that the profit attribution addition was deleted and the refund interest was taxable under Article 11(2) of the India-Singapore Tax Treaty. en-us Mon, 28 Oct 2024 00:00:00 +0530 Tue, 07 Jul 2026 21:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469862 Where the Indian associated enterprise has already been remunerated at arm's length for the covered transactions, no further profit attribution is warranted to the foreign enterprise merely on the basis of an alleged business connection or dependent agent permanent establishment in India. Interest on income-tax refund is not effectively connected with the permanent establishment on either an asset test or an activity test, so Article 7 does not exclude it and the treaty provision on interest income applies. The commentary therefore states that the profit attribution addition was deleted and the refund interest was taxable under Article 11(2) of the India-Singapore Tax Treaty. Case-Laws Income Tax Mon, 28 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469862