S. 44C : Non-residents-Head office expenditure-Head office expenses-Allocated to PE in India-Allowed full-Prior to amendment of article 7(3) of India-UAE DTAA by way of protocol dated 28-11-2007-Expenditure incurred outside India exclusively for operations of Indian branches would not fall within ambit of section 44C-Allowable in full-DTAA-India-UAE [Art. 7]