https://www.taxtmi.com/caselaws?id=795351 Expatriate salaries incurred exclusively for an Indian branch's business are deductible under section 37(1) and Article 7 of the India-UK DTAA, without section 44C restriction. Intra-entity interest between the branch and head office is not taxable and does not trigger withholding disallowance. Allocated support costs were allowable where supported by allocation keys and did not transfer protected rights or make available technical knowledge; they were neither royalty nor fees for technical services. Leasehold refurbishment and consistently recognised forward-contract revaluation losses were deductible. Section 14A disallowance was limited to 1% of exempt income. Head-office expenditure requires item-wise examination under section 44C and, where applicable, treaty non-discrimination provisions; transfer-pricing rules apply to enterprise-permanent-establishment transactions. en-us Thu, 16 Jul 2026 00:00:00 +0530 Tue, 21 Jul 2026 08:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795351 Expatriate salaries incurred exclusively for an Indian branch's business are deductible under section 37(1) and Article 7 of the India-UK DTAA, without section 44C restriction. Intra-entity interest between the branch and head office is not taxable and does not trigger withholding disallowance. Allocated support costs were allowable where supported by allocation keys and did not transfer protected rights or make available technical knowledge; they were neither royalty nor fees for technical services. Leasehold refurbishment and consistently recognised forward-contract revaluation losses were deductible. Section 14A disallowance was limited to 1% of exempt income. Head-office expenditure requires item-wise examination under section 44C and, where applicable, treaty non-discrimination provisions; transfer-pricing rules apply to enterprise-permanent-establishment transactions. Case-Laws Income Tax Thu, 16 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795351