https://www.taxtmi.com/caselaws?id=252016 Salary paid abroad to expatriate employees working exclusively for the Indian permanent establishment was held outside the head office expenditure restriction in section 44C, so the disallowance was deleted. Interest paid to the head office and overseas branches was allowed under the treaty framework, while interest received from them was held not taxable under mutuality principles, subject to limited section 14A recomputation. Section 115JB was held inapplicable to a foreign bank whose Indian accounts were not drawn under Parts II and III of Schedule VI, and deferred bank guarantee commission was taxable only when it crystallised. Issues on external commercial borrowing interest were remanded for fresh examination, and the treaty-rate challenge was rejected. en-us Fri, 19 Sep 2014 00:00:00 +0530 Thu, 25 Sep 2014 18:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252016 Salary paid abroad to expatriate employees working exclusively for the Indian permanent establishment was held outside the head office expenditure restriction in section 44C, so the disallowance was deleted. Interest paid to the head office and overseas branches was allowed under the treaty framework, while interest received from them was held not taxable under mutuality principles, subject to limited section 14A recomputation. Section 115JB was held inapplicable to a foreign bank whose Indian accounts were not drawn under Parts II and III of Schedule VI, and deferred bank guarantee commission was taxable only when it crystallised. Issues on external commercial borrowing interest were remanded for fresh examination, and the treaty-rate challenge was rejected. Case-Laws Income Tax Fri, 19 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252016