https://www.taxtmi.com/caselaws?id=327447 Under the India-France DTAA, the non-discrimination claim for a tax rate parity with domestic companies and co-operative banks was rejected because prior coordinate bench rulings already covered the point. The treaty treatment of an Indian branch's interest payments to its head office and overseas branches was distinguished from domestic law: the permanent establishment fiction applies only to profit attribution, and internal branch charges were not taxable in India as separate interest income. The article also states that marketing service remuneration does not accrue until the consideration is finalised and quantifiable, and related delay interest cannot arise before the underlying liability crystallises. en-us Thu, 31 Mar 2016 00:00:00 +0530 Mon, 20 Jul 2026 15:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327447 Under the India-France DTAA, the non-discrimination claim for a tax rate parity with domestic companies and co-operative banks was rejected because prior coordinate bench rulings already covered the point. The treaty treatment of an Indian branch's interest payments to its head office and overseas branches was distinguished from domestic law: the permanent establishment fiction applies only to profit attribution, and internal branch charges were not taxable in India as separate interest income. The article also states that marketing service remuneration does not accrue until the consideration is finalised and quantifiable, and related delay interest cannot arise before the underlying liability crystallises. Case-Laws Income Tax Thu, 31 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327447