Where AO justified the taxability of related interest income in the hands of assessee, on the ground that Indian representative office of the bank and the bank itself are two separate entities under Article 11 of Indo-German treaty. It was held that the bank and representative office were only one taxable unit, thus the same income shall not be taxed twice. (AY. 2014-15)
DZ Bank AG-India Representative v. Dy.CIT (2020) 196 DTR 209 / 208 TTJ 1081 (Mum.)(Trib.)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Indian representative office and the bank itself are one unit-They are taxed only once-DTAA-India-German. [S. 2(31), 253, Art.7, 11]