Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Interest arising on internal placements between an Indian branch and its head office or overseas branches was treated as a payment to self and not taxable income; interest from other overseas banks also escaped tax because the statutory condition for source-based taxation was not met, and the specific interest provision excluded resort to the general charging provision. Disallowances under section 14A failed where concessional-rate interest remained taxable, and also where interest-free funds covered exempt-income investments. Broken period interest on securities held as stock-in-trade, year-end foreign exchange revaluation loss, club membership fee for employees, and CRR/SLR shortfall payment were all held allowable. Interest charged on refund processing was not sustained, and bad debt write-back was remitted only for verification of prior taxation.
Interest arising on internal placements between an Indian branch and its head office or overseas branches was treated as a payment to self and not taxable income; interest from other overseas banks also escaped tax because the statutory condition for source-based taxation was not met, and the specific interest provision excluded resort to the general charging provision. Disallowances under section 14A failed where concessional-rate interest remained taxable, and also where interest-free funds covered exempt-income investments. Broken period interest on securities held as stock-in-trade, year-end foreign exchange revaluation loss, club membership fee for employees, and CRR/SLR shortfall payment were all held allowable. Interest charged on refund processing was not sustained, and bad debt write-back was remitted only for verification of prior taxation.
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