https://www.taxtmi.com/caselaws?id=306855 The Tribunal considered multiple transfer-pricing and treaty issues in a foreign company's tax appeal. It held that the higher tax rate for foreign companies did not violate the India-France treaty non-discrimination clause and followed earlier years' rulings against that claim. It also treated data processing fees paid by Indian branches to the Singapore branch, and interest payable by Indian branches to the head office and overseas branches, as intra-entity payments not taxable in India. Claims for further TDS credit and deletion of interest under section 234A were remanded for factual verification. The challenge to initiation of penalty proceedings was rejected as premature. en-us Mon, 04 Jan 2021 00:00:00 +0530 Thu, 02 Mar 2023 20:59:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306855 The Tribunal considered multiple transfer-pricing and treaty issues in a foreign company's tax appeal. It held that the higher tax rate for foreign companies did not violate the India-France treaty non-discrimination clause and followed earlier years' rulings against that claim. It also treated data processing fees paid by Indian branches to the Singapore branch, and interest payable by Indian branches to the head office and overseas branches, as intra-entity payments not taxable in India. Claims for further TDS credit and deletion of interest under section 234A were remanded for factual verification. The challenge to initiation of penalty proceedings was rejected as premature. Case-Laws Income Tax Mon, 04 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306855