https://www.taxtmi.com/caselaws?id=795351 Expatriate salaries incurred exclusively for an Indian branch are described as deductible under section 37(1) and Article 7 of the India-UK DTAA, rather than subject to section 44C. Intra-entity interest between the branch and head office is treated as a payment to self, without withholding or disallowance consequences. The note supports restricting section 14A disallowance to 1% of exempt income where consistently applied. Head-office expenditure requires factual classification under section 44C and possible consideration of Article 26(2). It states that transfer-pricing rules apply to enterprise-permanent-establishment dealings, while substantiated support costs are neither royalty nor fees for technical services if the make-available condition is unmet. Leasehold refurbishment and consistently revalued forward-contract losses are treated as deductible revenue or trading expenditure. 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 are described as deductible under section 37(1) and Article 7 of the India-UK DTAA, rather than subject to section 44C. Intra-entity interest between the branch and head office is treated as a payment to self, without withholding or disallowance consequences. The note supports restricting section 14A disallowance to 1% of exempt income where consistently applied. Head-office expenditure requires factual classification under section 44C and possible consideration of Article 26(2). It states that transfer-pricing rules apply to enterprise-permanent-establishment dealings, while substantiated support costs are neither royalty nor fees for technical services if the make-available condition is unmet. Leasehold refurbishment and consistently revalued forward-contract losses are treated as deductible revenue or trading expenditure. Case-Laws Income Tax Thu, 16 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795351