Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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