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Interest paid by Foreign Co. on borrowed funds for asset used in Indian projects was allowable as deduction

June 12, 2019[2019] 105 152 (Ahmedabad - Trib.)

INTERNATIONAL TAXATION : Where assessee, a Dubai based company, entered into agreement with Indian Company to carry out petroleum operations in India and, pursuant to said agreement assessee purchased an oil rig with borrowed funds and transferred said rig to its Indian project office, since interest expenses claimed by assessee were directly attributable to operations carried out by it in India, same was eligible for a deduction against income of assessee as per Explanation 3 to section 9 and DTAA between India and UAE

INTERNATIONAL TAXATION : Assessee was eligible to set off brought forward losses against current income computed on presumption basis under section 44BB(1)

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