Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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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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