https://www.taxtmi.com/highlights?id=96059 Whether costs incurred by the Head Office for procurement of software are deductible in computing the business profits of a permanent establishment in India under Article 7(3) of the India-Singapore DTAA: applying precedent (including Supreme Court and ITAT authority), the tribunal found that where the PE was exclusively established to distribute the procured software and the HO made the software available to the PE on a cost-to-cost basis, such procurement costs are bona fide business expenses and therefore allowable as deductions; consequently the PE's business profits were reduced by those costs and the appeal was allowed. - ITAT en-us Thu, 15 Jan 2026 18:08:49 +0530 Thu, 15 Jan 2026 18:08:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96059 Whether costs incurred by the Head Office for procurement of software are deductible in computing the business profits of a permanent establishment in India under Article 7(3) of the India-Singapore DTAA: applying precedent (including Supreme Court and ITAT authority), the tribunal found that where the PE was exclusively established to distribute the procured software and the HO made the software available to the PE on a cost-to-cost basis, such procurement costs are bona fide business expenses and therefore allowable as deductions; consequently the PE's business profits were reduced by those costs and the appeal was allowed. - ITAT Highlights Income Tax Thu, 15 Jan 2026 18:08:49 +0530 https://www.taxtmi.com/highlights?id=96059