Interest from Indian Permanent Establishment to Head Office is Taxable, No Exclusion for Mutuality Concept.

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 received by PE is deemed to be income of PE and there is no bar in the treaty on its taxability then it cannot be excluded from computation of income earned by PE - AT .....

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