https://www.taxtmi.com/caselaws?id=119510 Article 7(3) of the India-UAE treaty was read with article 25(1) to preserve domestic income-tax restrictions unless the treaty expressly displaced them, so disallowances such as entertainment, travel and provident fund limits continued to apply in computing profits attributable to a permanent establishment. The non-discrimination clause was construed by reference to a proper comparator of the same legal character, so a foreign bank's permanent establishment was comparable with a domestic company and not with an Indian co-operative society. Interest levied under section 12B of the Interest-tax Act was treated as compensatory and deductible, following the character of the principal interest tax levy. en-us Fri, 13 Apr 2007 00:00:00 +0530 Thu, 25 Jan 2024 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=119510 Article 7(3) of the India-UAE treaty was read with article 25(1) to preserve domestic income-tax restrictions unless the treaty expressly displaced them, so disallowances such as entertainment, travel and provident fund limits continued to apply in computing profits attributable to a permanent establishment. The non-discrimination clause was construed by reference to a proper comparator of the same legal character, so a foreign bank's permanent establishment was comparable with a domestic company and not with an Indian co-operative society. Interest levied under section 12B of the Interest-tax Act was treated as compensatory and deductible, following the character of the principal interest tax levy. Case-Laws Income Tax Fri, 13 Apr 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=119510