https://www.taxtmi.com/caselaws?id=282105 Retrospective clarification under section 90 was applied to preserve the higher tax rate for foreign companies, so the India-France Treaty non-discrimination clause did not secure domestic-company tax treatment for the assessee. Payments by an Indian branch to its head office or overseas branches for data processing charges and interest were treated as intra-entity transfers, or payments to self, and were not taxable in India on the footing of royalties, fees for technical services or interest. The Tribunal followed its earlier rulings on both points, rejected the parity claim, deleted the additions, and dismissed both appeals. en-us Mon, 16 Oct 2017 00:00:00 +0530 Mon, 22 Jul 2019 11:01:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=282105 Retrospective clarification under section 90 was applied to preserve the higher tax rate for foreign companies, so the India-France Treaty non-discrimination clause did not secure domestic-company tax treatment for the assessee. Payments by an Indian branch to its head office or overseas branches for data processing charges and interest were treated as intra-entity transfers, or payments to self, and were not taxable in India on the footing of royalties, fees for technical services or interest. The Tribunal followed its earlier rulings on both points, rejected the parity claim, deleted the additions, and dismissed both appeals. Case-Laws Income Tax Mon, 16 Oct 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=282105