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HC determined two key issues regarding NRI deposit mobilization expenses and pension fund contributions. Expenses incurred for soliciting NRI deposits were held deductible as they were exclusively for Indian business operations, following precedent set in ANZ Grindlays. On pension fund contributions exceeding Section 36(1)(iv) limits, HC distinguished between initial qualifying contributions and additional employer obligations, adopting Exide Industries rationale that statutory limits apply only to regular annual contributions, not supplementary payments meeting broader obligations. Additional contributions beyond prescribed limits remain allowable business expenses. Revenue's appeal dismissed, affirming tribunal's findings in assessee's favor on both counts.
HC determined two key issues regarding NRI deposit mobilization expenses and pension fund contributions. Expenses incurred for soliciting NRI deposits were held deductible as they were exclusively for Indian business operations, following precedent set in ANZ Grindlays. On pension fund contributions exceeding Section 36(1)(iv) limits, HC distinguished between initial qualifying contributions and additional employer obligations, adopting Exide Industries rationale that statutory limits apply only to regular annual contributions, not supplementary payments meeting broader obligations. Additional contributions beyond prescribed limits remain allowable business expenses. Revenue's appeal dismissed, affirming tribunal's findings in assessee's favor on both counts.
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