Held that interest paid by Indian Branch of assessee-Japanese bank to its overseas head office was not chargeable to tax in India (AY. 2012-13 to 2017-18)
DCIT v. Mizuho Bank Ltd. (2023) 199 ITD 523 (Mum.)(Trib.)
S. 9(1)(v) : Income deemed to accrue or arise in India-Interest-Interest paid by Indian Branch of assessee-Japanese bank to its overseas head office was not chargeable to tax in India-DTAA-India-Japan [Art. 11]