https://www.taxtmi.com/caselaws?id=796318 Interest paid by an Indian permanent establishment to its head office or overseas branches may be deductible in attributing profits under the applicable treaty, although domestic law treats it as a payment to self and does not tax the corresponding receipt separately. Transactions between a foreign enterprise and its Indian permanent establishment may require arm's-length analysis where transfer-pricing conditions are met. A guarantee-fee adjustment is confined to the shortfall from the arm's-length price after crediting commission received. Gains from forward contracts directly hedging capital investments retain capital character. Tax-refund interest not effectively connected with the permanent establishment may be taxed under the treaty interest article. A treaty-capped tax rate cannot be increased by surcharge or education cess. en-us Wed, 29 Jul 2026 00:00:00 +0530 Tue, 04 Aug 2026 08:39:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796318 Interest paid by an Indian permanent establishment to its head office or overseas branches may be deductible in attributing profits under the applicable treaty, although domestic law treats it as a payment to self and does not tax the corresponding receipt separately. Transactions between a foreign enterprise and its Indian permanent establishment may require arm's-length analysis where transfer-pricing conditions are met. A guarantee-fee adjustment is confined to the shortfall from the arm's-length price after crediting commission received. Gains from forward contracts directly hedging capital investments retain capital character. Tax-refund interest not effectively connected with the permanent establishment may be taxed under the treaty interest article. A treaty-capped tax rate cannot be increased by surcharge or education cess. Case-Laws Income Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796318