No Tax on Interest accrued/ received by Indian PE from its HO/ overseas branches

MUFG Bank Ltd. Vs ACIT (International Taxation) (ITAT Delhi) With respect to the addition on account of the interest received by Indian branches from head office and other overseas branches amounting to ₹ 3,499,476/–. During the year , assessee has received an interest of ₹ 3,499,476 from its head office and overseas branches. The assessee has included this income in its computation of total income however during the assessment proceedings it is claimed that this amount should be excluded from its income being payment to self and hence same is not taxable. It was submitted by the assesse...