Interest Taxability for Indian Branches: Limited Independence in PE Profit Calculations, Not Head Office or Overseas Branches.

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....Income taxable in India - Taxability of interest paid by the Indian branch office to the other overseas branches of the assessee - the fiction of hypothetical independence of the PE and head office/overseas branch cannot be extended to the computation of the profit of the head office/overseas branch, and the same is restricted only for computation of profit attributable to the PE. - AT....