https://www.taxtmi.com/caselaws?id=472430 Head-office directors' remuneration and fees allocated to an Indian permanent establishment qualify as executive and general administrative expenditure under Section 44C where a certified turnover-based allocation remains within the statutory ceiling. Article 7 of the India-Singapore tax treaty permits deduction of permanent-establishment expenses incurred in India or elsewhere, subject to domestic-law limits. Section 44C operates independently of inconsistent provisions in Sections 28 to 43A through its non obstante clause. A common head-office expense allocation cannot be rejected merely because it is notional when it is properly certified and within the statutory limit. en-us Mon, 21 Apr 2025 00:00:00 +0530 Tue, 13 Oct 2026 04:47:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472430 Head-office directors' remuneration and fees allocated to an Indian permanent establishment qualify as executive and general administrative expenditure under Section 44C where a certified turnover-based allocation remains within the statutory ceiling. Article 7 of the India-Singapore tax treaty permits deduction of permanent-establishment expenses incurred in India or elsewhere, subject to domestic-law limits. Section 44C operates independently of inconsistent provisions in Sections 28 to 43A through its non obstante clause. A common head-office expense allocation cannot be rejected merely because it is notional when it is properly certified and within the statutory limit. Case-Laws Income Tax Mon, 21 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472430