https://www.taxtmi.com/caselaws?id=470676 For the relevant pre-protocol years, the treaty provision allowing deduction of expenses attributable to an Indian permanent establishment governed over the domestic-law ceiling because the protocol imposing that limitation applied only prospectively from 1 April 2008. Revaluation losses on unmatured forward foreign-exchange contracts entered in the ordinary course of banking were deductible under the prudence principle. Gross interest on specified tax-free securities was exempt. Commission from mobilisation of Indian Millennium Deposits was computable as treaty business profits, with related overseas procurement and connected expenditure allowable; as no taxable income remained, withholding-based disallowance did not apply. en-us Fri, 08 May 2015 00:00:00 +0530 Tue, 04 Aug 2026 17:20:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470676 For the relevant pre-protocol years, the treaty provision allowing deduction of expenses attributable to an Indian permanent establishment governed over the domestic-law ceiling because the protocol imposing that limitation applied only prospectively from 1 April 2008. Revaluation losses on unmatured forward foreign-exchange contracts entered in the ordinary course of banking were deductible under the prudence principle. Gross interest on specified tax-free securities was exempt. Commission from mobilisation of Indian Millennium Deposits was computable as treaty business profits, with related overseas procurement and connected expenditure allowable; as no taxable income remained, withholding-based disallowance did not apply. Case-Laws Income Tax Fri, 08 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470676