https://www.taxtmi.com/caselaws?id=361930 Branch-head office interest is treated as a payment to self for Indian tax purposes where the treaty position creates no contrary charge. It is deductible in computing branch income, and no tax deduction at source applies where the corresponding amount is not taxable to the head office in India. Year-end revaluation loss on outstanding foreign-exchange forward contracts is allowable rather than contingent or merely notional. Payments arising from security-deal limit shortfalls remain deductible where compensatory and not for an offence or prohibited by law. Interest from FII investments not attributable to an Indian permanent establishment is governed by the applicable treaty interest article rather than business-income treatment. 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 Branch-head office interest is treated as a payment to self for Indian tax purposes where the treaty position creates no contrary charge. It is deductible in computing branch income, and no tax deduction at source applies where the corresponding amount is not taxable to the head office in India. Year-end revaluation loss on outstanding foreign-exchange forward contracts is allowable rather than contingent or merely notional. Payments arising from security-deal limit shortfalls remain deductible where compensatory and not for an offence or prohibited by law. Interest from FII investments not attributable to an Indian permanent establishment is governed by the applicable treaty interest article rather than business-income treatment. Case-Laws Income Tax Fri, 15 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361930