Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
In banking-tax matters, intra-entity interest received by an Indian branch from its head office and overseas branches was treated as internal allocation, not real income, because the deeming rule for interest could not be stretched to a transaction with oneself; the addition was deleted. Centralised hub service charges for data processing, monitoring and risk support were held to be direct operational costs, not restricted head office overheads, and the disallowance was deleted. Broken period interest, mark-to-market loss on unmatured forward contracts, and diminution in value of securities held as stock-in-trade were each allowed as revenue deductions. Reimbursement of expatriate salary was also upheld as branch-specific cost, while the exempt-income disallowance ground was dismissed.
In banking-tax matters, intra-entity interest received by an Indian branch from its head office and overseas branches was treated as internal allocation, not real income, because the deeming rule for interest could not be stretched to a transaction with oneself; the addition was deleted. Centralised hub service charges for data processing, monitoring and risk support were held to be direct operational costs, not restricted head office overheads, and the disallowance was deleted. Broken period interest, mark-to-market loss on unmatured forward contracts, and diminution in value of securities held as stock-in-trade were each allowed as revenue deductions. Reimbursement of expatriate salary was also upheld as branch-specific cost, while the exempt-income disallowance ground was dismissed.
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