https://www.taxtmi.com/caselaws?id=234363 The High Court dismissed the Review Petition regarding the Revenue's Appeal for Assessment Year 1994-95. The Court upheld the decision based on the Deutsche Bank AG case, applying the pre-amended Section 44C of the Income Tax Act, which allowed for a more favorable deduction for head office expenses. The Court considered the Double Taxation Avoidance Agreement between Germany and India, emphasizing the relevance of international agreements in determining tax liabilities. The Review Petition was dismissed with no order as to costs, reaffirming the application of the precedent set in the Deutsche Bank AG case. en-us Tue, 26 Mar 2013 00:00:00 +0530 Sat, 08 Jun 2013 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234363 The High Court dismissed the Review Petition regarding the Revenue's Appeal for Assessment Year 1994-95. The Court upheld the decision based on the Deutsche Bank AG case, applying the pre-amended Section 44C of the Income Tax Act, which allowed for a more favorable deduction for head office expenses. The Court considered the Double Taxation Avoidance Agreement between Germany and India, emphasizing the relevance of international agreements in determining tax liabilities. The Review Petition was dismissed with no order as to costs, reaffirming the application of the precedent set in the Deutsche Bank AG case. Case-Laws Income Tax Tue, 26 Mar 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234363