Month: August 2013

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

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