Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights March 2023 Year 2023 This

Income taxable in India - Taxability of interest paid by the ...

Case Laws     Income Tax

March 29, 2023

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

View Source

 


 

You may also like:

  1. Taxability of interest payable/paid by the Indian branch office to the head office and its other overseas branches - even though the submission of the Revenue that the...

  2. Disallowance of interest paid to Head Office - Non deduction of TDS - assessee submitted that Assessing Officer held that interest income is taxable under DTAA at 10% in...

  3. Interest paid to the head office of the assessee bank as well as its overseas branches by the Indian branch cannot be taxed in India being payment to self - AT

  4. The Delhi High Court examined taxability in India of interest received by an Indian Permanent Establishment (PE) from its Head Office/Overseas Branch under the India-US...

  5. Taxability of Interest paid by the branch (PE) in India to its parent foreign bank in Japan - Deduction of interest so paid as expenditure - the interest income received...

  6. Services being provided by the branch office in India to the Head Office in USA - income earned by the assessee from the activities carried on by it is taxable in India - AT

  7. Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against...

  8. Interest accrued/received to the Indian PE from its head office/overseas branches – concept of mutuality cannot override specific provision of law - once the interest...

  9. There is a clear distinction between the NOSTRO interest earned/paid by the assessee from/to its own Head office/overseas branches and NOSTRO interest paid/earned...

  10. Interest paid to Head office (Japanese banking company) by assessee (PE-Indian branch) - not chargeable to tax in India. - AT

  11. Taxability of salary income earned by non-residents from Indian companies. In this Judgement, it was determined that under Section 9(1)(ii) of the Income Tax Act, salary...

  12. TP adjustment on account of payment of overseas support fee - The assessee has its head office outside India and the decision, on the basis of which the assessee gets...

  13. Transfer pricing adjustment - transaction between a head office in a foreign country and its branch office in India - principle of mutuality - it is axiomatic that...

  14. Income taxable In India - Taxability of compensation paid to the overseas Cricket Association for the termination of the agreement - Dependent Agent Permanent...

  15. 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...

 

Quick Updates:Latest Updates