https://www.taxtmi.com/caselaws?id=215204 A treaty amendment introducing a domestic-law limitation into the computation of permanent establishment profits operates prospectively unless the treaty expressly provides otherwise; accordingly, section 44C did not restrict head office expenses under Article 7(3) of the Indo-UAE treaty for the relevant years. The article also notes related tax computation positions: interest under section 244A is to be calculated on the refund without reducing earlier interest, exemption under section 10(15) applies to gross receipts, guarantee commission accrues over the guarantee period, valuation losses on investments may be allowed where cost or market value principles are applied, and bad debt deduction is computed without the Revenue's improper set-off of the closing provision. en-us Fri, 20 Jul 2012 00:00:00 +0530 Mon, 09 May 2016 15:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215204 A treaty amendment introducing a domestic-law limitation into the computation of permanent establishment profits operates prospectively unless the treaty expressly provides otherwise; accordingly, section 44C did not restrict head office expenses under Article 7(3) of the Indo-UAE treaty for the relevant years. The article also notes related tax computation positions: interest under section 244A is to be calculated on the refund without reducing earlier interest, exemption under section 10(15) applies to gross receipts, guarantee commission accrues over the guarantee period, valuation losses on investments may be allowed where cost or market value principles are applied, and bad debt deduction is computed without the Revenue's improper set-off of the closing provision. Case-Laws Income Tax Fri, 20 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215204