Tax on interest received by Indian PE on deposit maintained with Head Office/Overseas Branch

Commissioner of Income Tax-International Taxation-3 Vs Bank of Tokyo-Mitsubishi UFJ Ltd. (Delhi High Court)

The case of Commissioner of Income Tax vs Bank of Tokyo-Mitsubishi UFJ Ltd. before the Delhi High Court raises crucial questions regarding the taxation of interest received by Indian Permanent Establishments (PE) on deposits maintained with the Head Office or Overseas Branch. This article provides a detailed analysis of the judgment and its implications.

The central issue in this case revolves around whether the interest received by the Permanent Establishment of the B

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