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Referral charges paid to Indian Branch of 'Credit Suisse' to Foreign Branch not taxable in India as FTS

May 6, 2019[2019] 104 339 (Mumbai)/[2019] 176 ITD 873 (Mumbai)

IT/ILT: Where Dubai based branch of assessee, a foreign bank, received referral charges from its Indian Branch for referring a resident client to Indian branch for bringing out issue of convertible bonds, amount so received was not liable to tax in India as fee for technical services

IT/ILT: Interest paid by Indian branch of foreign bank to Head Office is neither deductible in hand of Indian Branch nor chargeable to tax in hand of Head Office and overseas branches as they constitute a single entity
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