https://www.taxtmi.com/caselaws?id=180467 An Indian resident is taxable on global income under section 5(1)(c), so profits of the assessee's USA branch were not excluded from Indian taxation. The treaty provisions did not create an exemption: Article 7 dealt with attribution of profits to a permanent establishment, while Article 25.2(a) provided relief only by way of foreign tax credit for tax paid in the United States. The operative effect was application of the credit method rather than complete exemption, and the issue was decided in favour of the Revenue. en-us Tue, 27 Nov 2007 00:00:00 +0530 Fri, 25 Mar 2016 15:41:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180467 An Indian resident is taxable on global income under section 5(1)(c), so profits of the assessee's USA branch were not excluded from Indian taxation. The treaty provisions did not create an exemption: Article 7 dealt with attribution of profits to a permanent establishment, while Article 25.2(a) provided relief only by way of foreign tax credit for tax paid in the United States. The operative effect was application of the credit method rather than complete exemption, and the issue was decided in favour of the Revenue. Case-Laws Income Tax Tue, 27 Nov 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180467