Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
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Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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