https://www.taxtmi.com/caselaws?id=178811 Domestic-law limits on deductibility, including section 44C, continued to apply when computing the Indian permanent establishment profits of a UAE resident bank under Article 7 of the India-UAE DTAA because the treaty contained no express contrary rule for the period in question. The later protocol amendment was treated as clarificatory, not a basis to displace those restrictions retrospectively. On MAT, section 115JB did not apply to a banking company for the relevant assessment year because the provision then depended on accounts prepared under Parts II and III of Schedule VI, which did not govern banks in the same way; the MAT addition was therefore deleted. en-us Fri, 15 Jan 2016 00:00:00 +0530 Sat, 08 Feb 2025 10:31:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178811 Domestic-law limits on deductibility, including section 44C, continued to apply when computing the Indian permanent establishment profits of a UAE resident bank under Article 7 of the India-UAE DTAA because the treaty contained no express contrary rule for the period in question. The later protocol amendment was treated as clarificatory, not a basis to displace those restrictions retrospectively. On MAT, section 115JB did not apply to a banking company for the relevant assessment year because the provision then depended on accounts prepared under Parts II and III of Schedule VI, which did not govern banks in the same way; the MAT addition was therefore deleted. Case-Laws Income Tax Fri, 15 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178811