Post existence of PE, expense incurred by PE can be set off against connected income

SIS Live Vs ACIT (ITAT Delhi)

ITAT Delhi held that as Permanent Establishment (PE) exists, interest income being connected to the PE, has to be treated as business profit under Article 7 of the treaty. Accordingly, expenses incurred has to be set off against the interest income.

Facts- The core issue arising for consideration is whether the assessee has a Permanent Establishment (PE) in India so as to entitle the assessee to claim certain expenses as well as other benefits

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