https://www.taxtmi.com/caselaws?id=215204 Article 7(3) of the Indo-UAE treaty, as applicable before the protocol amendment, permitted deduction of expenses incurred for the permanent establishment without the domestic-law restriction in section 44C. The later protocol limitation operated prospectively from its stated effective date, and the treaty's double-taxation relief provision did not import domestic-law computation restrictions. Interest on refunds was to be computed on the tax refund without reducing the principal base by interest previously paid. Exemption for specified interest applied to gross receipts; guarantee commission accrued over the guarantee period; investment valuation loss was allowable under the lower-of-cost-or-market method; and bad-debt deductions required correct statutory computation without the Revenue's closing-provision set-off method. 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 Article 7(3) of the Indo-UAE treaty, as applicable before the protocol amendment, permitted deduction of expenses incurred for the permanent establishment without the domestic-law restriction in section 44C. The later protocol limitation operated prospectively from its stated effective date, and the treaty's double-taxation relief provision did not import domestic-law computation restrictions. Interest on refunds was to be computed on the tax refund without reducing the principal base by interest previously paid. Exemption for specified interest applied to gross receipts; guarantee commission accrued over the guarantee period; investment valuation loss was allowable under the lower-of-cost-or-market method; and bad-debt deductions required correct statutory computation without the Revenue's closing-provision set-off method. Case-Laws Income Tax Fri, 20 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215204