Tax on Interest Income & commitment fees earned by DZ Bank from its Indian clients

DZ Bank AG – India Representative Office Vs DCIT (ITAT Mumbai) Interest Income & commitment fees earned by DZ Bank from its Indian clients could be taxed under article 11 instead of article 7 of Indian Branch under Tax Treaty: Conclusion: Interest income and commitment fees earned by DZ Bank from its Indian clients could be taxed at the hands of Indian Branch under India Germany Tax Treaty  under article 11 , and not additionally under article 7 also, but the income was taxable nevertheless, subject to the exemptions set out in and under the scheme of article 11, on gross basis. Held: T...