Interest income to be taxed @10% as per India-Japan DTAA

DCIT Vs Marubeni Corporation (ITAT Mumbai) Held that the interest income in question is required to be taxed at 10% in terms of the provisions of Article 11(2) of the India-Japan DTAA Facts- The assessee is a company incorporated in, and fiscally domiciled in, the Republic of Japan. The interest income was offered by the assessee to be tax at the rate of 10% in terms of the provisions of Article 11(2) of the India Japan Double Taxation Avoidance Agreement. In the course of scrutiny assessment proceedings, AO noted that the assessee admittedly has a permanent establishment in India and that, in...