Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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.
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