Tribunal rules in favor of foreign bank PE on key tax and transfer pricing issues.
Tribunal rules in favor of foreign bank PE on key tax and transfer pricing issues. Issues Section 44C vs. Section 37(1) Disallowance: Whether direct head office/overseas branch (HO/OB) expenses incurred on behalf of the Indian Permanent Establishment (PE) are subject to restriction under Section 44C or are fully allowable under Section 37(1). Taxability of Branch-to-HO… Read More »