https://www.taxtmi.com/caselaws?id=799537 Indian PE taxation of a foreign bank remains at foreign-company rates where domestic-company conditions are unmet and Article 24(2) does not apply because domestic and foreign companies are not similarly situated. Under Article 7, PE-head-office dealings are treated separately for profit attribution, but interest remitted overseas requires TDS compliance under section 195; non-compliance triggers disallowance under section 40(a)(i). Conversely, interest received by the PE from overseas offices forms taxable PE business income. ATMs performing digital data processing, software functions, and network communication fall within the computer category for depreciation. en-us Tue, 22 Sep 2026 00:00:00 +0530 Wed, 23 Sep 2026 08:48:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799537 Indian PE taxation of a foreign bank remains at foreign-company rates where domestic-company conditions are unmet and Article 24(2) does not apply because domestic and foreign companies are not similarly situated. Under Article 7, PE-head-office dealings are treated separately for profit attribution, but interest remitted overseas requires TDS compliance under section 195; non-compliance triggers disallowance under section 40(a)(i). Conversely, interest received by the PE from overseas offices forms taxable PE business income. ATMs performing digital data processing, software functions, and network communication fall within the computer category for depreciation. Case-Laws Income Tax Tue, 22 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799537