https://www.taxtmi.com/caselaws?id=70032 Treaty allocation under the India-Malaysia agreement governed the taxation of a resident company's Malaysian plantation profits and Indian interest income. Business profits attributable to the Malaysian permanent establishment were taxable only to the extent permitted by Article 7, so the Malaysian plantation income could not be brought into Indian computation as an Indian business loss or used for inter-head set-off. Indian office expenditure connected with that foreign enterprise was treated as attributable to the Malaysian business, not as a separate Indian loss. Interest earned in India was separately covered by Article 12 and, where no expenditure was incurred to earn it, was taxable in full under the residuary head. en-us Mon, 28 Jun 1993 00:00:00 +0530 Wed, 13 Apr 2011 15:48:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70032 Treaty allocation under the India-Malaysia agreement governed the taxation of a resident company's Malaysian plantation profits and Indian interest income. Business profits attributable to the Malaysian permanent establishment were taxable only to the extent permitted by Article 7, so the Malaysian plantation income could not be brought into Indian computation as an Indian business loss or used for inter-head set-off. Indian office expenditure connected with that foreign enterprise was treated as attributable to the Malaysian business, not as a separate Indian loss. Interest earned in India was separately covered by Article 12 and, where no expenditure was incurred to earn it, was taxable in full under the residuary head. Case-Laws Income Tax Mon, 28 Jun 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70032