Interest paid by a branch of a Foreign Bank to its Head Office is deductible in the hands of the branch

ABN AMRO Bank NV Vs. CIT I.T.A. NO. 458 OF 2005 HIGH COURT AT CALCUTTA Judgment on: 23rd December 2010 Judgment This is an Appeal under Section 260A of the Income Tax Act, 1961 (in short “the Act”) against the Order of the Income Tax Appellate Tribunal (in short “the tribunal”) dated 22nd August 2005. Before discussing the merits of this Appeal, a reference to section 90 of the Act is necessary. It empowers the Central Government to enter into an agreement with a foreign government to interalia avoid double taxation in India as well as in that foreign country. In such case where an agr...