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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...

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