OrbitaxTreaty between India and Japan – Indian decision on whether losses incurred by PE of Indian company in Japan could be reduced from taxable income in India
|Treaty Development|India-Japan
The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 29 June 2007 in the cases of Deputy Commissioner of Income Tax v. Patni Computer Systems Ltd (109 TTJ 742) on whether losses incurred by a foreign branch of an Indian company are eligible to be set off against the company's taxable income in India.
(a) Facts. The Taxpayer (i.e. Patni…
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