Tax on Interest Income & commitment fees earned by DZ Bank from its Indian clients

DZ Bank AG – India Representative Office Vs DCIT (ITAT Mumbai)

Interest Income & commitment fees earned by DZ Bank from its Indian clients could be taxed under article 11 instead of article 7 of Indian Branch under Tax Treaty:

Conclusion: Interest income and commitment fees earned by DZ Bank from its Indian clients could be taxed at the hands of Indian Branch under India Germany Tax Treaty  under article 11 , and not additionally under article 7 also, but the income was taxable

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