Notional Interest on loan to AE assessable as income, if assessee having PE in India

Sabre Asia Pacific Pte. Ltd. Vs DCIT (ITAT Mumbai)

The issue under consideration is whether notional interest income on the loan (interest-free) that was advanced by the assessee to its AE would be assessable as the income of the assessee which has a business connection or Permanent Establishment (PE) in India?

ITAT states that in respect of such international transactions, the domestic bank rate would not be a sound basis and rather internationally accepted LIBOR rate wou

Please become a Premium member. If you are already a Premium member, login here to access the full content.