https://www.taxtmi.com/caselaws?id=239755 A treaty-based non-discrimination clause cannot be used to extend a domestic-law deduction unless the claimant satisfies the statutory conditions for that deduction and is similarly placed in the same circumstances as the comparator taxpayer. On that basis, section 80M relief was unavailable to the foreign bank under the India-France DTAA. The provision for interest on bad and doubtful debts and the repairs and maintenance claim were remanded for fresh factual verification, including consistency with earlier years and supporting records. For the later year, the Tribunal treated the Rules 6D and 6B, section 37(2), section 43B and club-payment disallowances as unsustainable on the treaty footing applied to business profits. en-us Thu, 28 Feb 2013 00:00:00 +0530 Mon, 18 Nov 2013 15:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239755 A treaty-based non-discrimination clause cannot be used to extend a domestic-law deduction unless the claimant satisfies the statutory conditions for that deduction and is similarly placed in the same circumstances as the comparator taxpayer. On that basis, section 80M relief was unavailable to the foreign bank under the India-France DTAA. The provision for interest on bad and doubtful debts and the repairs and maintenance claim were remanded for fresh factual verification, including consistency with earlier years and supporting records. For the later year, the Tribunal treated the Rules 6D and 6B, section 37(2), section 43B and club-payment disallowances as unsustainable on the treaty footing applied to business profits. Case-Laws Income Tax Thu, 28 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239755