Interest on fixed deposits effectively connected with PE is taxable as Business Income

Interest on fixed deposits effectively connected with PE – Business Income; Direct expenses incurred by a head office for Indian projects – not Head office expense; Fees for procurement services – not taxable as ‘fees for technical services’ In brief :-In a recent ruling in the case of DDIT Vs. Samsung Engineering Co. Ltd. [2010-T11-169-ITAT¬MUM-INTL], the Mumbai Income-tax Appellate Tribunal (the “Tribunal”), held that (i) interest on a fixed deposit kept as margin with banks, which is effectively connected with a permanent establishment (“PE”...