https://www.taxtmi.com/caselaws?id=470638 Interest paid by Indian bank branches to their head office or overseas branches is deductible in computing permanent-establishment profits under the applicable treaty, although treated as a payment to self under domestic law; the related disallowance was deleted. Year-end foreign-exchange revaluation losses on outstanding forward contracts were treated as allowable business expenditure, while unsupported net exchange losses remained subject to partial disallowance. Interest on Government bonds acquired by the head office as FII was not effectively connected with the Indian permanent establishment and was assessable under the treaty interest article. Bad-debt provision and brought-forward loss claims require fresh computation under the applicable specific rules and prior appellate effects. en-us Mon, 12 Feb 2018 00:00:00 +0530 Mon, 03 Aug 2026 14:54:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470638 Interest paid by Indian bank branches to their head office or overseas branches is deductible in computing permanent-establishment profits under the applicable treaty, although treated as a payment to self under domestic law; the related disallowance was deleted. Year-end foreign-exchange revaluation losses on outstanding forward contracts were treated as allowable business expenditure, while unsupported net exchange losses remained subject to partial disallowance. Interest on Government bonds acquired by the head office as FII was not effectively connected with the Indian permanent establishment and was assessable under the treaty interest article. Bad-debt provision and brought-forward loss claims require fresh computation under the applicable specific rules and prior appellate effects. Case-Laws Income Tax Mon, 12 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470638