Article 7 cannot come into play unless interest income is directly or indirectly attributable to PE

DCIT Vs Marubeni Corporation (ITAT Mumbai)

On the facts of this case, however, all that the Assessing Officer has indicated is that the assessee had a permanent establishment (PE) in India during the relevant period and that there was presumably some connection between the interest income of the assessee and the existence of the permanent establishment. There is nothing to elaborate upon the nature of the connection, except for the vague generalities, or to even prima facie indicate that the connection was such that

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