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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Finance Bill 2020 amends section 94B, excluding non-resident bank PE debt interest from deduction limits. Effective April 2021.</h1> The Finance Bill 2020 proposes an amendment to section 94B of the Income Tax Act, which limits interest deductions exceeding one crore rupees to 30% of EBITDA for Indian companies or foreign company PEs. This amendment excludes interest paid on debt issued by a Permanent Establishment (PE) of a non-resident bank in India from these limitations. The change addresses concerns regarding the classification of foreign bank branches as non-residents and their potential classification as associated enterprises (AE) under section 92A. This amendment is effective from April 1, 2021, applicable for the assessment year 2021-22 onwards.
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