International TaxArticle·14 July 2026
ITAT Deletes Tax on Self Interest
By J the App
Executive Summary
The ITAT held that interest credited by a foreign bank’s Head Office to its Indian branch is not taxable in India, as it represents an internal transaction within the same legal entity.
It ruled that the deeming fiction under the India–USA DTAA treating a Permanent Establishment as a separate enterprise applies only for profit attribution and cannot create a new tax liability.
Domain | Direct Tax | International Tax
Background
The assessee, a bank...
Read the full article in the app
This is a premium article. Download J the App to read the complete content.