https://www.taxtmi.com/caselaws?id=71312 Treaty non-discrimination requires comparable taxpayers to receive equal treatment and does not invalidate a domestic tax incentive distinction based on residence where it has a rational nexus with the statutory objective. Restricting the export incentive under section 80HHE to residents was treated as non-arbitrary because it supports domestic foreign-exchange retention; the foreign permanent establishment was therefore not entitled to the deduction. Loss from a section 10A eligible unit was eligible for set-off against other business profits. Deduction for head-office expenditure under section 44C was not available because the material did not provide verifiable particulars for computing expenditure attributable to Indian operations. en-us Wed, 10 Sep 2008 00:00:00 +0530 Sat, 09 Dec 2023 20:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71312 Treaty non-discrimination requires comparable taxpayers to receive equal treatment and does not invalidate a domestic tax incentive distinction based on residence where it has a rational nexus with the statutory objective. Restricting the export incentive under section 80HHE to residents was treated as non-arbitrary because it supports domestic foreign-exchange retention; the foreign permanent establishment was therefore not entitled to the deduction. Loss from a section 10A eligible unit was eligible for set-off against other business profits. Deduction for head-office expenditure under section 44C was not available because the material did not provide verifiable particulars for computing expenditure attributable to Indian operations. Case-Laws Income Tax Wed, 10 Sep 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71312