https://www.taxtmi.com/caselaws?id=241053 Expenditure directly attributable to Indian operations of a non-resident's overseas branches was treated as outside the stricter head office cap under section 44C, while treaty protection under Article 7(3) did not override domestic limits on allowable business . Interest paid to tax authorities was not eligible for netting against interest received from them. The commentary also notes allowance of compensatory payments to the central bank for reserve shortfall and non-compliance, employee-related club fees, and a proportion of entertainment expenditure linked to staff accompanying clients. Guest house outlays remained disallowable, exempt-income common expenditure required fresh examination, and head office expenditure for a later year needed reconsideration on proper certificate scrutiny. en-us Wed, 27 Nov 2013 00:00:00 +0530 Mon, 16 Dec 2013 17:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=241053 Expenditure directly attributable to Indian operations of a non-resident's overseas branches was treated as outside the stricter head office cap under section 44C, while treaty protection under Article 7(3) did not override domestic limits on allowable business . Interest paid to tax authorities was not eligible for netting against interest received from them. The commentary also notes allowance of compensatory payments to the central bank for reserve shortfall and non-compliance, employee-related club fees, and a proportion of entertainment expenditure linked to staff accompanying clients. Guest house outlays remained disallowable, exempt-income common expenditure required fresh examination, and head office expenditure for a later year needed reconsideration on proper certificate scrutiny. Case-Laws Income Tax Wed, 27 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=241053