https://www.taxtmi.com/caselaws?id=327716 A tax treaty override analysis concludes that the treaty governs unless domestic law is more beneficial to the taxpayer, applying the treaty override principle and the most beneficial rule; consequence: the Indo-US DTAA prevails over contrary provisions of the Act. The domestic provision treating certain administrative payments as disallowable was found discriminatory and inapplicable under the treaty non-discrimination provision, with the result that an administrative fee was deductible. Expenses accruing in prior accounting periods were held to be deductible in the assessment year in which the liability arose, with corresponding allowances granted for the relevant assessment years. en-us Fri, 13 May 2016 00:00:00 +0530 Wed, 14 Jan 2026 18:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327716 A tax treaty override analysis concludes that the treaty governs unless domestic law is more beneficial to the taxpayer, applying the treaty override principle and the most beneficial rule; consequence: the Indo-US DTAA prevails over contrary provisions of the Act. The domestic provision treating certain administrative payments as disallowable was found discriminatory and inapplicable under the treaty non-discrimination provision, with the result that an administrative fee was deductible. Expenses accruing in prior accounting periods were held to be deductible in the assessment year in which the liability arose, with corresponding allowances granted for the relevant assessment years. Case-Laws Income Tax Fri, 13 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327716