TMI Blog2015 (7) TMI 1127X X X X Extracts X X X X X X X X Extracts X X X X ..... laimed benefit of the double taxation avoidance agreement. See DIT (Intnl. Txn.) v. Credit Agricole Indosuez [2015 (6) TMI 974 - BOMBAY HIGH COURT ] Tribunal is correct in holding that section 44C is not applicable and these expenses are allowable and under section 37(1) of the Income-tax Act. See Commissioner of Income-Tax Versus Emirates Commercial Bank Ltd. [2003 (4) TMI 2 - BOMBAY HIGH COUR ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rcumstances of the case and in law, the Tribunal was correct in holding that addition on account of inter est received from head office has been wrongly made by the Assess ing Officer ? 3. The only other question being urged by him for admission in both the assessment years before us is question No. 3 as formulated in both appeal memos which is renumbered herein as question No. 2 and reads as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 (Bom) being question No. 5 therein. In this case similar to that in M/s. Credit Agricole Indosuez, the respondent-assessee has not claimed benefit of the double taxation avoidance agreement. Accordingly, question No. 1 as formulated does not give rise to any question of law and thus, we do not entertain it. 5. So far as question No. 2 is concerned, the impugned order of the Tribunal has follo ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
