https://www.taxtmi.com/caselaws?id=283320 An Indian permanent establishment was allowed deduction for expatriate salaries paid abroad by the head office where the employees worked in India and the expense was wholly and exclusively attributable to the Indian branch. Interest credited by the branch on balances with its head office and overseas branches was treated as not taxable because the head office and branch were regarded as the same taxable person. Interest on external commercial borrowings arranged for Indian borrowers was also held not separately taxable in the assessee's hands. The text further notes remand of the section 244A refund-interest issue and transfer pricing adjustments based on undisclosed section 133(6) material, and rejects any rate challenge above domestic company rates. en-us Mon, 11 Jun 2018 00:00:00 +0530 Thu, 19 Sep 2019 08:18:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=283320 An Indian permanent establishment was allowed deduction for expatriate salaries paid abroad by the head office where the employees worked in India and the expense was wholly and exclusively attributable to the Indian branch. Interest credited by the branch on balances with its head office and overseas branches was treated as not taxable because the head office and branch were regarded as the same taxable person. Interest on external commercial borrowings arranged for Indian borrowers was also held not separately taxable in the assessee's hands. The text further notes remand of the section 244A refund-interest issue and transfer pricing adjustments based on undisclosed section 133(6) material, and rejects any rate challenge above domestic company rates. Case-Laws Income Tax Mon, 11 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=283320