https://www.taxtmi.com/caselaws?id=765786 Under the India-UAE tax treaty, Article 7(3) was treated as permitting deduction of all expenses attributable to a permanent establishment, including executive and general administrative expenses, without importing the section 44C ceiling for the relevant pre-Protocol period. The later Protocol, effective from 01.04.2008, was read as a prospective substantive change, confirming that the earlier treaty text did not itself adopt the domestic restriction. Expenses incurred outside India exclusively for Indian branch operations were also held not to be head office expenditure; as branch-specific costs, they were deductible in full and outside section 44C. en-us Thu, 06 Feb 2025 00:00:00 +0530 Mon, 18 Aug 2025 14:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765786 Under the India-UAE tax treaty, Article 7(3) was treated as permitting deduction of all expenses attributable to a permanent establishment, including executive and general administrative expenses, without importing the section 44C ceiling for the relevant pre-Protocol period. The later Protocol, effective from 01.04.2008, was read as a prospective substantive change, confirming that the earlier treaty text did not itself adopt the domestic restriction. Expenses incurred outside India exclusively for Indian branch operations were also held not to be head office expenditure; as branch-specific costs, they were deductible in full and outside section 44C. Case-Laws Income Tax Thu, 06 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765786