https://www.taxtmi.com/caselaws?id=369202 Article 7(3) of the Indo-Mauritius DTAA permits deduction of expenses of a permanent establishment for business purposes without importing restrictions from section 40(a)(i) of the Income Tax Act. Applying that treaty interpretation, the ITAT Delhi upheld deletion of disallowances for non-deduction of TDS on salary paid to employees and on operating contract expenses, as the treaty did not permit domestic TDS-based restriction to be read into the expense claim. The Tribunal also sustained deletion of additions for travel and entertainment expenses because the assessee had furnished supporting reimbursement records and the revenue identified no specific defect. The Rule 46A objection was rejected because the record showed relevant details were already before the AO. en-us Fri, 05 Oct 2018 00:00:00 +0530 Tue, 23 Oct 2018 06:51:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=369202 Article 7(3) of the Indo-Mauritius DTAA permits deduction of expenses of a permanent establishment for business purposes without importing restrictions from section 40(a)(i) of the Income Tax Act. Applying that treaty interpretation, the ITAT Delhi upheld deletion of disallowances for non-deduction of TDS on salary paid to employees and on operating contract expenses, as the treaty did not permit domestic TDS-based restriction to be read into the expense claim. The Tribunal also sustained deletion of additions for travel and entertainment expenses because the assessee had furnished supporting reimbursement records and the revenue identified no specific defect. The Rule 46A objection was rejected because the record showed relevant details were already before the AO. Case-Laws Income Tax Fri, 05 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=369202