Interest Income on Supplier Credit to Indian Entities Requires Clear Attribution to Permanent Establishment for Tax Purposes.

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....Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee has received interest income are also the clients of the assessee in India with whom contracts were executed through the Permanent Establishment in India and the assessee has received fees for technical services in a previous year from them, but then the performance of contracts through the PE or receipt of fees for technical services from such clients is irrelevant as long as the interest income is not demonstrated to be attributable to the permanent establishment. Such an attribution cannot be inferred or assumed - AT....