India-UAE DTAA Prevails: ITAT Allows 100% Deduction for Head Office Expenses, Bypasses Section 44C Restrictions [Read Order]
The ITAT held that the India-UAE DTAA specifically allows for a deduction of all reasonable executive and general administrative expenses and that this clause would be rendered ineffective if the restriction under Section 44C is applied
By Adwaid M S - On May 8, 2025 2:52 pm - 2 mins read
The Mumbai Bench of the Income Tax Appellate Tribunal ( ITAT ) has held that the limitation under Section 44C of the Income Tax Act, 1961, is overridden by the provisions of the India-UAE Double Taxation Avoidance Agreement ( DTAA ), allowing a full deduction of head office expenses claimed by a foreign bank’s Indian…
Your free access to Taxscan has Expired
To read the article, get a premium account.
Taxscan Premium
Why should you subscribe?
Enjoy our website without interruptions from advertisements
Receive Daily newsletters
Receive realtime Telegram/Whatsapp news updates
Download original Judgements / Order / Notifications / Circulars, etc
