Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Disallowance under the interest-attributable rule is held unsustainable where shares are held as stock-in-trade; amortisation of lease premium is capital in nature, with depreciation to be allowed. Income of overseas branches is includible in Indian taxable income, with foreign tax credit available to the extent admissible under applicable tax treaties and domestic credit rules; computation must follow treaty and local law for credit purposes. Deductions for bad debts written off and amortisation of HTM losses are allowed; broken period interest on securities held as stock-in-trade is revenue expenditure; interest on NPAs not recognised until credited or received; loss on sale to ARC is allowable; penalty for regulatory breach by foreign branch is nondeductible under business expense rules.
Disallowance under the interest-attributable rule is held unsustainable where shares are held as stock-in-trade; amortisation of lease premium is capital in nature, with depreciation to be allowed. Income of overseas branches is includible in Indian taxable income, with foreign tax credit available to the extent admissible under applicable tax treaties and domestic credit rules; computation must follow treaty and local law for credit purposes. Deductions for bad debts written off and amortisation of HTM losses are allowed; broken period interest on securities held as stock-in-trade is revenue expenditure; interest on NPAs not recognised until credited or received; loss on sale to ARC is allowable; penalty for regulatory breach by foreign branch is nondeductible under business expense rules.
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