https://www.taxtmi.com/caselaws?id=214945 Foreign exchange earned from overseas projects was treated as eligible for deduction under section 80HHB on the full amount, because the receipts were used in part to repay foreign currency borrowings taken for executing those projects and the deduction was applied on the basis that the remittance obligation remained linked to the same foreign earnings. Profits attributable to the assessee's permanent establishment in Oman were excluded from Indian taxation under article 7 of the India-Oman DTAA, as the income had been taxed in Oman and was governed by the treaty allocation rule for business profits of a foreign permanent establishment. en-us Thu, 16 Oct 2008 00:00:00 +0530 Tue, 15 Mar 2016 14:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214945 Foreign exchange earned from overseas projects was treated as eligible for deduction under section 80HHB on the full amount, because the receipts were used in part to repay foreign currency borrowings taken for executing those projects and the deduction was applied on the basis that the remittance obligation remained linked to the same foreign earnings. Profits attributable to the assessee's permanent establishment in Oman were excluded from Indian taxation under article 7 of the India-Oman DTAA, as the income had been taxed in Oman and was governed by the treaty allocation rule for business profits of a foreign permanent establishment. Case-Laws Income Tax Thu, 16 Oct 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214945