Held that foreign company are not prepared in accordance with Part II and Part III of Schedule-VI of Companies Act, 1956 and their accounts are not being laid in annual general meeting before shareholders of company for approval, provisions of section 115JB cannot be made applicable to a foreign company. Accordingly the MAT provisions cannot apply where tax treaty is invoked as provisions of section 115JB are only subordinate to section 90(2) and section 90(2) overrides section 115JB.  MAT provisions could not be applied even to foreign companies which have PE in India as it would be contrary to basic foundation of applicable treaty.  (AY. 2015-16)