https://www.taxtmi.com/caselaws?id=119285 The India-UAE tax treaty was read as preserving domestic deduction restrictions for profits attributable to a permanent establishment unless the treaty expressly provides otherwise, so the disallowances sustained by the first appellate authority on that point were upheld. The non-discrimination clause was held not to require parity with a differently constituted domestic entity, and the higher rate applicable to foreign companies was sustained. However, year-end loss on unmatured forward foreign exchange contracts was allowed as an ascertainable business loss, and travelling expenses connected with interior decoration work remained revenue in character and were deductible because they did not create an enduring asset. en-us Thu, 23 Aug 2007 00:00:00 +0530 Sat, 13 Jan 2024 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=119285 The India-UAE tax treaty was read as preserving domestic deduction restrictions for profits attributable to a permanent establishment unless the treaty expressly provides otherwise, so the disallowances sustained by the first appellate authority on that point were upheld. The non-discrimination clause was held not to require parity with a differently constituted domestic entity, and the higher rate applicable to foreign companies was sustained. However, year-end loss on unmatured forward foreign exchange contracts was allowed as an ascertainable business loss, and travelling expenses connected with interior decoration work remained revenue in character and were deductible because they did not create an enduring asset. Case-Laws Income Tax Thu, 23 Aug 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=119285