https://www.taxtmi.com/caselaws?id=800900 Direct HO/OB expenditure specifically attributable to an Indian branch is distinguishable from general head-office expenditure and may be considered under section 37(1), subject to evidence and allocation verification, rather than the section 44C cap. Under the India-France DTAA, interest paid by an Indian branch to its HO/OB is not independently taxable within the same enterprise, and treaty rate ceilings for interest and FTS exclude additional surcharge and cess. Transfer-pricing analysis of marketing, guarantee and common-cost transactions requires prescribed methods, functional benchmarking and avoidance of duplicate disallowance. ECB-interest computation must avoid double taxation after PE attribution, while tax deducted at source credit and consequential interest require verification and recomputation. en-us Thu, 08 Oct 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800900 Direct HO/OB expenditure specifically attributable to an Indian branch is distinguishable from general head-office expenditure and may be considered under section 37(1), subject to evidence and allocation verification, rather than the section 44C cap. Under the India-France DTAA, interest paid by an Indian branch to its HO/OB is not independently taxable within the same enterprise, and treaty rate ceilings for interest and FTS exclude additional surcharge and cess. Transfer-pricing analysis of marketing, guarantee and common-cost transactions requires prescribed methods, functional benchmarking and avoidance of duplicate disallowance. ECB-interest computation must avoid double taxation after PE attribution, while tax deducted at source credit and consequential interest require verification and recomputation. Case-Laws Income Tax Thu, 08 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800900