https://www.taxtmi.com/caselaws?id=306841 The Tribunal held that the non-discrimination article in the India-France treaty did not extend the domestic tax rate applicable to domestic companies and co-operative banks to the assessee, so that claim failed. It further applied earlier coordinate bench and Special Bench rulings that a payment by an Indian branch to its foreign head office or overseas branch is a payment to self and does not give rise to taxable income in India under the royalty or fees for technical services article; the data processing fee addition was therefore deleted. The TDS credit claim was not rejected, but remanded for verification and grant in accordance with law after hearing the assessee. en-us Mon, 22 Apr 2019 00:00:00 +0530 Thu, 02 Mar 2023 08:15:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306841 The Tribunal held that the non-discrimination article in the India-France treaty did not extend the domestic tax rate applicable to domestic companies and co-operative banks to the assessee, so that claim failed. It further applied earlier coordinate bench and Special Bench rulings that a payment by an Indian branch to its foreign head office or overseas branch is a payment to self and does not give rise to taxable income in India under the royalty or fees for technical services article; the data processing fee addition was therefore deleted. The TDS credit claim was not rejected, but remanded for verification and grant in accordance with law after hearing the assessee. Case-Laws Income Tax Mon, 22 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306841