https://www.taxtmi.com/caselaws?id=282104 Article notes two India-France treaty issues under ITAT Mumbai. First, the assessee's request for tax parity with domestic companies and co-operative banks under the non-discrimination article was rejected, following earlier coordinate bench rulings in the same matter. Second, data processing charges paid by an Indian branch to its foreign head office were treated as internal charges within one enterprise; because the services were effectively connected with the permanent establishment, taxation was governed by the business profits attribution framework rather than the royalty or fees-for-technical-services article. On that basis, the related amount was not brought to tax in the hands of the head office, and the appeal succeeded only on this issue. en-us Thu, 31 Mar 2016 00:00:00 +0530 Mon, 22 Jul 2019 11:01:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=282104 Article notes two India-France treaty issues under ITAT Mumbai. First, the assessee's request for tax parity with domestic companies and co-operative banks under the non-discrimination article was rejected, following earlier coordinate bench rulings in the same matter. Second, data processing charges paid by an Indian branch to its foreign head office were treated as internal charges within one enterprise; because the services were effectively connected with the permanent establishment, taxation was governed by the business profits attribution framework rather than the royalty or fees-for-technical-services article. On that basis, the related amount was not brought to tax in the hands of the head office, and the appeal succeeded only on this issue. Case-Laws Income Tax Thu, 31 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=282104