Interest income from loans given to Indian parties, not attributable to assessee’s PE is taxable at 10% under the India-Japan DTAA.

Saturday International Tax Gyan!! (SITG – 255) #taxmadeeasy #taxinpic

ITAT Mumbai Branch ‘I’ ACIT v. Marubeni Corporation [2025] 173 taxmann.com 441 (Mumbai – Trib.)

Assessee earned interest income from loans given to Indian parties, which was not attributable to its PE; hence, taxable at 10% under the India-Japan DTAA despite the presence of the PE in India.