Shanti Prime Publication Pvt. Ltd.
Section 90 of the Income Tax Act, 1961—DTAA—By virtue of article 24(2) of Indo Japan DTAA and the statutory recognition thereof section 90(2) the PE of a Japanese bank in India has to be regarded as a domestic company and could not be charged to tax at rate higher than the applicable to a domestic company—Bank of Tokyo Mitsubishi Ltd. vs. Commissioner of income tax [2019] 310 CTR (Calcutta) 479