[aaykarbhavan] The Law On Deductibility Of H. O. Expenses Of A Permanent Establishment

Dear Subscriber,

The Law On Deductibility Of H. O. Expenses Of A Permanent Establishment

CA Sumeet Khurana, Joint Director, Lakshmikumaran & Sridharan

The author explains the delicate interplay between s. 44C of the Act and Article 7(3) of the DTAA on the deductibility of H. O. expenses incurred by a Permanent Establishment (PE). He explores the scope of the non-discriminatory mandate in Article 7(3) of the DTAA & examines the extent to which it overrides s. 44C. He also reviews the several judgements on the point and argues that some of them are wrong and require reconsideration 

(Click Here To Read More)

 

Regards,

 

Editor,

 

itatonline.org

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