Set off of loss of PE against interest income from External Commercial Borrowing allowed

Abu Dhabi Commercial Bank PJSC We work India Management Private Limited Vs DCIT (International Taxation) 1(1)(1) (ITAT Mumbai) ITAT Mumbai held that set off of loss of Permanent Establishment [PE] against the interest income received from External Commercial Borrowing, on which benefit of concessional rate tax availed, is allowable. Accordingly, appeal allowed to that extent. Facts- The assessee is a non-resident banking company having its head office in United Arab Emirates (‘U.A.E’ for short) and is a tax resident of U.A.E. In course of assessment proceeding, the A.O., while verifying th...