https://www.taxtmi.com/caselaws?id=282098 Under the India-France tax treaty non-discrimination clause, the Tribunal followed earlier orders in the assessee's own case and coordinate bench rulings and rejected the claim to the domestic company and co-operative bank tax rate. On data processing fees booked between the Indian branch and Singapore branch, it held that a foreign enterprise and its branch or permanent establishment are not separate taxable units for this purpose, so an internal charge is a payment to self. Because the amounts were effectively connected with the permanent establishment, taxation was confined to business profits attributable to that permanent establishment; the addition was deleted and only partial relief was granted. en-us Thu, 31 Mar 2016 00:00:00 +0530 Mon, 22 Jul 2019 06:26:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=282098 Under the India-France tax treaty non-discrimination clause, the Tribunal followed earlier orders in the assessee's own case and coordinate bench rulings and rejected the claim to the domestic company and co-operative bank tax rate. On data processing fees booked between the Indian branch and Singapore branch, it held that a foreign enterprise and its branch or permanent establishment are not separate taxable units for this purpose, so an internal charge is a payment to self. Because the amounts were effectively connected with the permanent establishment, taxation was confined to business profits attributable to that permanent establishment; the addition was deleted and only partial relief was granted. Case-Laws Income Tax Thu, 31 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=282098