Income taxable in India - Taxability of interest paid by the ...
Interest Taxability for Indian Branches: Limited Independence in PE Profit Calculations, Not Head Office or Overseas Branches.
March 29, 2023
Case Laws Income Tax AT
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