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Assessee has raised the ground that the learned DCIT erred in holding that the appellant had a business connection in India in terms of the Act and a permanent establishment [PE] in India in terms of the India-Singapore Double Taxation Avoidance Agreement [DTAA].

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Sec. 92C of Income Tax Act, 1961—Transfer Pricing - Notional interest income on the loan (interest free) that was advanced by the assessee to its AE would be assessable as the income of the assessee which has a business connection/PE in India and the said notional interest income on the loans advanced by the assessee to its AE would be entitled to be adjusted against the expenditure incurred by the assessee by way of marketing service fees paid to its National Marketing Agency in India - SABRE ASIA PACIFIC (PTE.) LTD. V/s DY. CIT - [2020] 183 ITD 832 (ITAT-MUMBAI)