https://www.taxtmi.com/caselaws?id=471965 IT support and management-service charges paid by an Indian branch to its head office are deductible where they are genuine business expenses, satisfy section 37 conditions, and are not among the Protocol-specified excluded payments; Article 7 supports their deduction in determining permanent establishment profits. Regional managerial, consultancy, back-office and IT support payments to Singapore and Australian group entities are not treaty fees for technical services unless they make available independently usable technical capability. Recurring services requiring continued human intervention fail that test, preventing withholding obligations and section 40(a)(i) disallowance. An actuarially determined reserve for unexpired risk, reduced from premium income, is an ascertained liability outside section 115JB book-profit add-backs. en-us Tue, 15 Apr 2025 00:00:00 +0530 Thu, 24 Sep 2026 19:22:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471965 IT support and management-service charges paid by an Indian branch to its head office are deductible where they are genuine business expenses, satisfy section 37 conditions, and are not among the Protocol-specified excluded payments; Article 7 supports their deduction in determining permanent establishment profits. Regional managerial, consultancy, back-office and IT support payments to Singapore and Australian group entities are not treaty fees for technical services unless they make available independently usable technical capability. Recurring services requiring continued human intervention fail that test, preventing withholding obligations and section 40(a)(i) disallowance. An actuarially determined reserve for unexpired risk, reduced from premium income, is an ascertained liability outside section 115JB book-profit add-backs. Case-Laws Income Tax Tue, 15 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471965