Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
The High Court upheld the Tribunal's decision regarding the allowability of expenses incurred for garnering FCNR deposits to be maintained at the assessee bank's Indian branches. The funds mobilized abroad were brought to India in foreign currency accounts and kept for the Indian business. The benefits accrued to the Indian branch/Permanent Establishment were accounted for as Indian income, and the deduction of expenses incurred for procurement of business cannot be disallowed as Head Office expenses. Regarding credit card commission paid for cards issued by foreign branches and used in India, the Tribunal correctly held that the charges received by foreign branches for extending credit lines outside India would not be taxable in India, as the debt was incurred outside India.
The High Court upheld the Tribunal's decision regarding the allowability of expenses incurred for garnering FCNR deposits to be maintained at the assessee bank's Indian branches. The funds mobilized abroad were brought to India in foreign currency accounts and kept for the Indian business. The benefits accrued to the Indian branch/Permanent Establishment were accounted for as Indian income, and the deduction of expenses incurred for procurement of business cannot be disallowed as Head Office expenses. Regarding credit card commission paid for cards issued by foreign branches and used in India, the Tribunal correctly held that the charges received by foreign branches for extending credit lines outside India would not be taxable in India, as the debt was incurred outside India.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
