The Mumbai bench of India's Income Tax Appellate Tribunal (ITAT) issued an order on 6 February 2025 concerning the deduction of head office expenses under the 1992 India-UAE tax treaty, prior to its amendment by a 2007 protocol. The case involved Mashreq Bank, a UAE-based private bank, which had two branches in India. The Bank sought to fully deduct head office expenses for the 2002–2003 assessment year. This was denied by the tax authority considering section 44C of the Income Tax Act 1961, which limits the deduction of head office expenses to 5% of the adjusted total income. The Bank...