Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
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Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Overseas NRI Desk costs, including allocable staff, administrative, support, internal audit, financial control, IT, human resources, operations, rent, maintenance, depreciation and advertising expenses, fall within the Explanation to section 44C when incurred by a non-resident banking company. They are therefore treated as head office expenditure subject to the statutory limitation under section 44C, rather than direct business expenditure fully deductible under section 37(1). The disallowance of full deduction under section 37(1) was sustained, consistently with the settled treatment in earlier years and the cited Supreme Court authority.
Overseas NRI Desk costs, including allocable staff, administrative, support, internal audit, financial control, IT, human resources, operations, rent, maintenance, depreciation and advertising expenses, fall within the Explanation to section 44C when incurred by a non-resident banking company. They are therefore treated as head office expenditure subject to the statutory limitation under section 44C, rather than direct business expenditure fully deductible under section 37(1). The disallowance of full deduction under section 37(1) was sustained, consistently with the settled treatment in earlier years and the cited Supreme Court authority.
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