domestic law, this
approach seems to be at variance with the international practices wherein connotations of
'treaty override' refer to a situation
Barclays Bank and
represented by one global certificate. As per the international practice,
interest in global certificate and the bond is transferred through the system ... along assessee's stand is that
it is a global practice that a single global certificate of FCCB fund is issued and
registered
Acit Cen. Cir. 17 & 28, Mumbai vs M/S. J.B. Bada Offshore Surveyors
sine qua
non to taxability in that jurisdiction is a normal international
practice in all tax systems. This school of thought is now
specifically supported
charged is excessive and
ought to be reduced having regard to international practices.
GROUND V:
Taxation of Long Term Capital Gain:
1. On the facts ... which defines the term
"international transaction" used in section 92(1) of the Act as under:--
"International transaction means a transaction between
account as per Regulations and prudent business
practice and international practices being followed by assessee
company. AO's contention is based on amounts referred
clarified by the Ministry of Surface Transport that according to normal international practice and also according to the agreements with the foreign shipowners
internal law, expenses may be deducted (attributable to the permanent establishment) provided that the deductions are in accordance with the international practices. On this basis ... internal law, expenses may be deducted (attributable to the permanent establishment) provided that the deductions are in accordance with the international practices. In the present
account as per Regulations and prudent business
practice and international practices being followed by assessee
company. AO's contention is based on amounts referred
account as per Regulations and prudent business
practice and international practices being followed by assessee
company. AO's contention is based on amounts referred