Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty's separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer's borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors' accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.
Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty's separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer's borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors' accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.
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