| COURT: | Bombay High Court |
| CORAM: | M. S. Sanklecha J, N. M. Jamdar J |
| SECTION(S): | 244A |
| GENRE: | International Tax |
| CATCH WORDS: | 244A Interest, India-France DTAA, India-UK DTAA |
| COUNSEL: | Madhur Agrawal, Percy Pardiwala |
| DATE: | June 17, 2015 (Date of pronouncement) |
| DATE: | July 29, 2015 (Date of publication) |
| AY: | 1997-98 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| S. 244A: Interest on income-tax refund received by a non-resident is not effectively connected with the PE (Permanent Establishment) either on asset test or activity test. Accordingly such interest cannot be assessed as business profits but has to be assessed as "interest" under Article 11/ 12 | |
Interest on income tax refund is not effectively connected with the PE (Permanent Establishment) either on asset test or activity test. Therefore, taxable under the Article 11(2) of Indo Netherlands tax treaty
Recent Comments