Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
Income-tax exemption for specified regulatory fees and government grants applies subject to non-commercial activity and continuing compliance conditio...
Digital accessibility audit and remediation deadlines extended, while all other disability-compliance obligations for regulated entities remain unchan...
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The Tribunal held that interest received from or paid to head office and overseas branches on the NOSTRO account was a self-to-self transaction governed by mutuality, so it was not taxable in the permanent establishment's hands and the related disallowance failed. On head office expenditure, it restored the matter for fresh examination because the disputed items had to be tested on the Supreme Court's interpretation of the statutory concept of head office expenditure; the royalty issue was to be considered only if the items fell outside that concept. It upheld deletion of the exempt-income disallowance where surplus interest-free funds exceeded the investments, sustained deduction of broken period interest, treated ATM software expenditure as revenue, and held that income taxed on a special gross basis is not exempt income.
The Tribunal held that interest received from or paid to head office and overseas branches on the NOSTRO account was a self-to-self transaction governed by mutuality, so it was not taxable in the permanent establishment's hands and the related disallowance failed. On head office expenditure, it restored the matter for fresh examination because the disputed items had to be tested on the Supreme Court's interpretation of the statutory concept of head office expenditure; the royalty issue was to be considered only if the items fell outside that concept. It upheld deletion of the exempt-income disallowance where surplus interest-free funds exceeded the investments, sustained deduction of broken period interest, treated ATM software expenditure as revenue, and held that income taxed on a special gross basis is not exempt income.
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