Withdrawal of obsolete FEMA circulars streamlines rules on external commercial borrowings, non-resident bond investments, and money transfer sub-agent...
Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
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RBI regulatory monetary levies for non-compliance with lending guidelines may be deductible where the underlying default is supervisory in an otherwise lawful banking business, rather than an offence or prohibited activity; the levy was therefore not disallowed under Explanation 1 to section 37(1). Banking-company securities held as stock-in-trade did not attract expenditure disallowance for exempt dividend income under section 14A and Rule 8D. Net depreciation on investments valued under ICDS VIII and RBI guidelines was allowable because the prescribed method was followed. Employee stock-option discount was treated as revenue expenditure because it incentivises and retains employees without creating an enduring asset or constituting capital-raising expenditure.
RBI regulatory monetary levies for non-compliance with lending guidelines may be deductible where the underlying default is supervisory in an otherwise lawful banking business, rather than an offence or prohibited activity; the levy was therefore not disallowed under Explanation 1 to section 37(1). Banking-company securities held as stock-in-trade did not attract expenditure disallowance for exempt dividend income under section 14A and Rule 8D. Net depreciation on investments valued under ICDS VIII and RBI guidelines was allowable because the prescribed method was followed. Employee stock-option discount was treated as revenue expenditure because it incentivises and retains employees without creating an enduring asset or constituting capital-raising expenditure.
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