https://www.taxtmi.com/caselaws?id=122166 A foreign bank's income was held taxable at the higher rate applicable to non-resident companies because the treaty non-discrimination clause did not override the domestic statutory rate structure, and section 90's explanation treated that differential as permissible. Expenditure on purchase of fixed assets was not deductible in computing permanent establishment profits under the treaty, as those profits remained subject to the domestic law basis of computation. Donation payments were also disallowed because no sufficient evidence showed that they were wholly and exclusively incurred for business purposes or had a staff welfare nexus. en-us Fri, 25 Jun 2010 00:00:00 +0530 Thu, 09 Aug 2012 11:37:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122166 A foreign bank's income was held taxable at the higher rate applicable to non-resident companies because the treaty non-discrimination clause did not override the domestic statutory rate structure, and section 90's explanation treated that differential as permissible. Expenditure on purchase of fixed assets was not deductible in computing permanent establishment profits under the treaty, as those profits remained subject to the domestic law basis of computation. Donation payments were also disallowed because no sufficient evidence showed that they were wholly and exclusively incurred for business purposes or had a staff welfare nexus. Case-Laws Income Tax Fri, 25 Jun 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122166