Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
For a non-resident bank, overseas data-processing costs qualify as head office expenditure only where incurred outside India, constituting executive or general administration, and falling within the statutory definition; factual examination of those conditions was required. NRI desk expenditure remained disallowed. Where interest-free funds exceeded investments in exempt securities, investments were presumed funded from those sources, supporting exemption without interest disallowance. Bad-debt provision deduction must be computed before the head office expenditure deduction because it is not excluded from adjusted total income. Interest between an Indian branch and its head office or overseas branches is not taxable in India, so withholding-based disallowance does not apply; however, a deductor cannot obtain credit or refund of tax deducted absent statutory authority.
For a non-resident bank, overseas data-processing costs qualify as head office expenditure only where incurred outside India, constituting executive or general administration, and falling within the statutory definition; factual examination of those conditions was required. NRI desk expenditure remained disallowed. Where interest-free funds exceeded investments in exempt securities, investments were presumed funded from those sources, supporting exemption without interest disallowance. Bad-debt provision deduction must be computed before the head office expenditure deduction because it is not excluded from adjusted total income. Interest between an Indian branch and its head office or overseas branches is not taxable in India, so withholding-based disallowance does not apply; however, a deductor cannot obtain credit or refund of tax deducted absent statutory authority.
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