https://www.taxtmi.com/caselaws?id=215832 Article 25 of the India-Korea DTAA did not secure a foreign bank's entitlement to the lower tax rate applicable to resident taxpayers. Unrealised appreciation on current securities, valued consistently at cost or market value whichever is lower under the RBI framework, was excluded until realised. Upfront guarantee commission accrued when the guarantee was issued, subject to preventing double taxation where it was taxed later. Interest paid by an Indian branch to its head office was deductible in determining permanent-establishment profits, while the corresponding receipt was not taxable as a payment to self. Crystallised foreign-exchange contract losses were allowable, and expatriate salary exclusively attributable to the Indian branch was outside the section 44C limitation. en-us Wed, 27 Jun 2012 00:00:00 +0530 Fri, 07 Aug 2026 14:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215832 Article 25 of the India-Korea DTAA did not secure a foreign bank's entitlement to the lower tax rate applicable to resident taxpayers. Unrealised appreciation on current securities, valued consistently at cost or market value whichever is lower under the RBI framework, was excluded until realised. Upfront guarantee commission accrued when the guarantee was issued, subject to preventing double taxation where it was taxed later. Interest paid by an Indian branch to its head office was deductible in determining permanent-establishment profits, while the corresponding receipt was not taxable as a payment to self. Crystallised foreign-exchange contract losses were allowable, and expatriate salary exclusively attributable to the Indian branch was outside the section 44C limitation. Case-Laws Income Tax Wed, 27 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215832