03 January 2012
Here the issue is that Citibank Singapore and New Delhi Branch are the part of Citibank, New York and for the purpose of DTAA, India-USA and not India-Singapore DTAA shall be relevant.
THE PAN of Citibank India represents PAN of Citibank New York and that shall suffice the purpose of sec. 206AA however kindly take in writing from Citibank India that Citibank India was not involved in the loan transaction between Citibank Singapore and Indian party and no part of interest income payable to Citibank Singapore is attributable to Citibank India.
CAclubindia
