https://www.taxtmi.com/caselaws?id=799613 Under the India-Netherlands DTAA, an Indian permanent establishment of a foreign bank is not entitled to domestic-company tax rates merely under Article 24(2), because foreign-company taxation is not less favourable treatment. The Article 7 separate-entity approach treats cross-border interest between the permanent establishment and its head office or branches as attributable income and permits expense recognition only subject to withholding; failure to comply with tax deduction requirements causes disallowance. Automated teller machines may receive computer-rate depreciation where their data-processing functions meet the relevant asset classification. Vehicle lease rentals used for business remain revenue expenditure where the arrangement is hiring rather than acquisition; accounting treatment under AS 19 does not control tax deductibility. en-us Tue, 22 Sep 2026 00:00:00 +0530 Thu, 24 Sep 2026 08:27:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799613 Under the India-Netherlands DTAA, an Indian permanent establishment of a foreign bank is not entitled to domestic-company tax rates merely under Article 24(2), because foreign-company taxation is not less favourable treatment. The Article 7 separate-entity approach treats cross-border interest between the permanent establishment and its head office or branches as attributable income and permits expense recognition only subject to withholding; failure to comply with tax deduction requirements causes disallowance. Automated teller machines may receive computer-rate depreciation where their data-processing functions meet the relevant asset classification. Vehicle lease rentals used for business remain revenue expenditure where the arrangement is hiring rather than acquisition; accounting treatment under AS 19 does not control tax deductibility. Case-Laws Income Tax Tue, 22 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799613