Interest paid by Indian Branch to Its foreign HO allowable

DCIT Vs Mizuho Corporate Bank Ltd. (ITAT Mumbai) We shall now advert to the issue as regards the allowability of the interest paid by the branch of the assessee bank to its head office as an expenditure in the hands of the branch office. We find that the claim of the assessee as regards the interest expenditure was disallowed by the A.O, for the reason that he held a conviction that as the branch and head office of the assessee bank were not separate entities as per domestic law as well as DTAA, thus the payment of the interest by the branch office to its head office, being in the nature of a ...