Held that interest paid by Indian branch of foreign bank to Head Office is neither deductible in hands of Indian branch nor chargeable to tax in hand of Head Office and overseas branches as they constitute a single entity. (AY. 2015-16)
ACIT(IT) v. Credit Suisse AG. (2022) 197 ITD 209 (Mum.) (Trib.)
S. 9(1)(v) : Income deemed to accrue or arise in India-Interest-Transactions with Head Office-Paid by Indian branch of foreign bank to Head Office-Constitute a single entity-Neither deductible nor chargeable to tax-DTAA-India-Singapore. [Art. 7]