Where the assessee is a company incorporated in, and fiscally domiciled in, the Republic of Japan. The assessee, inter alia,earned income from interest on suppliers’ credit. It was held that mere existence of a permanent establishment of the assessee company in India does not attract higher rate of tax. The beneficial rate of tax as per Article 11(2) cannot be denied. ( ITA No.: 10/Mum/2022 dated June 17, 2022)  (Bench ‘I’ )(AY. 2016 -17)