Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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.
Note: It is a system-generated summary and is for quick reference only.