https://www.taxtmi.com/caselaws?id=361930 Indian branch interest paid to a foreign head office and overseas branches is analysed as a payment to self for tax purposes, with deductibility considered under section 36(1)(iii) and the treaty position under Articles 5 and 7; the note also states that no TDS is required where the sum is not taxable in India. It further explains that year-end loss on revaluation of outstanding foreign exchange forward contracts is allowable when the contracts remain unmatured, that a CCIL payment is compensatory rather than penal and so is not barred by the Explanation to section 37, and that FII interest from Indian securities is taxed under Article 11, not as business income, where the investment is not attributable to the PE. en-us Fri, 15 Jun 2018 00:00:00 +0530 Sat, 16 Jun 2018 10:55:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361930 Indian branch interest paid to a foreign head office and overseas branches is analysed as a payment to self for tax purposes, with deductibility considered under section 36(1)(iii) and the treaty position under Articles 5 and 7; the note also states that no TDS is required where the sum is not taxable in India. It further explains that year-end loss on revaluation of outstanding foreign exchange forward contracts is allowable when the contracts remain unmatured, that a CCIL payment is compensatory rather than penal and so is not barred by the Explanation to section 37, and that FII interest from Indian securities is taxed under Article 11, not as business income, where the investment is not attributable to the PE. Case-Laws Income Tax Fri, 15 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361930