https://www.taxtmi.com/caselaws?id=470239 India-UK treaty non-discrimination protection is described as preventing section 44C from restricting head-office expense deductions fairly attributable to an Indian permanent establishment where comparable domestic enterprises face no such cap. The notes also address deletion of withholding-related disallowances where recipients paid tax, and the non-taxability of branch payments to the same legal entity. Direct overseas operational costs, leasehold refurbishment and early-separation payments are treated as revenue deductions. They describe limited exempt-income disallowance where sufficient interest-free funds exist, non-applicability of section 115JA to a foreign bank, treaty-rate taxation of crystallised refund interest, and prevention of duplicate taxation of income already offered to tax. en-us Mon, 13 Nov 2023 00:00:00 +0530 Tue, 21 Jul 2026 14:30:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470239 India-UK treaty non-discrimination protection is described as preventing section 44C from restricting head-office expense deductions fairly attributable to an Indian permanent establishment where comparable domestic enterprises face no such cap. The notes also address deletion of withholding-related disallowances where recipients paid tax, and the non-taxability of branch payments to the same legal entity. Direct overseas operational costs, leasehold refurbishment and early-separation payments are treated as revenue deductions. They describe limited exempt-income disallowance where sufficient interest-free funds exist, non-applicability of section 115JA to a foreign bank, treaty-rate taxation of crystallised refund interest, and prevention of duplicate taxation of income already offered to tax. Case-Laws Income Tax Mon, 13 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470239