Assessee, non-resident bank, claimed deduction for interest paid by Indian PE to head office with respect to funds borrowed by PE from head office. Assessing Officer denied said claim on ground that branch and head office constituted same legal entity.  The   Assessing Officer also held that interest income received from head office was to be accounted for in profits attributable to PE. Tribunal held that  profits attributable to PE were to be computed on basis of hypothetical independence of PE from head office as provided in article 7(2) and, interest paid by PE was to be allowed as deduction and interest received by PE from head office was to be treated as its income.  (AY. 2012-13 to 2015-16)