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Interest paid by bank to its head office and branch located outside India not taxable before AY 2016-17: ITAT

March 17, 2020[2020] 114 taxmann.com 700 (Mumbai - Trib.)

INTERNATIONAL TAXATION : Explanation to section 9(1)(v)(c) inserted by Finance Act, 2015 with effect from 1-4-2016 would apply from assessment year 2016-17 onwards and; therefore, during assessment year 2012-13, interest paid by Indian branch of assessee non-resident bank to its Head Office and overseas branches being a payment to self would be governed by principle of mutuality and, therefore, same could not be brought to tax as per provision of section 9(1)(v)(c)

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