https://www.taxtmi.com/caselaws?id=784992 For computing profits attributable to a permanent establishment under the India-Singapore DTAA, expenses necessarily incurred for the PE's business must be allowed, and the PE is to be treated as a separate and independent enterprise for attribution purposes. Software procurement, maintenance and allied charges incurred through head-office debit memos were found to be integrally connected with the Indian branch's distribution activity and could not be denied merely because they were routed through the head office or represented reimbursements. The expenditure was therefore allowable in computing the business profits of the permanent establishment in India. en-us Fri, 09 Jan 2026 00:00:00 +0530 Thu, 15 Jan 2026 08:41:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784992 For computing profits attributable to a permanent establishment under the India-Singapore DTAA, expenses necessarily incurred for the PE's business must be allowed, and the PE is to be treated as a separate and independent enterprise for attribution purposes. Software procurement, maintenance and allied charges incurred through head-office debit memos were found to be integrally connected with the Indian branch's distribution activity and could not be denied merely because they were routed through the head office or represented reimbursements. The expenditure was therefore allowable in computing the business profits of the permanent establishment in India. Case-Laws Income Tax Fri, 09 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784992