https://www.taxtmi.com/caselaws?id=218484 Exclusive expenditure incurred wholly for Indian branches, including head office and NRI solicitation expenses, was treated as directly relatable branch expense and allowed in full under the general deduction provision, not capped by the common head office expense restriction. Expenditure linked to exempt bond interest and dividend income was held disallowable in principle, but the quantum had to be determined on a reasonable basis rather than by a purely mechanical computation, including where securities were held as stock-in-trade. Intra-organisational interest between head office and foreign branches was treated as a self-to-self transaction, so no taxable income arose and no deduction was allowed. Interest on bad or doubtful debts was governed by the timing rule for taxation, subject to verification and recomputation. en-us Fri, 10 Aug 2012 00:00:00 +0530 Wed, 01 Jul 2026 18:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218484 Exclusive expenditure incurred wholly for Indian branches, including head office and NRI solicitation expenses, was treated as directly relatable branch expense and allowed in full under the general deduction provision, not capped by the common head office expense restriction. Expenditure linked to exempt bond interest and dividend income was held disallowable in principle, but the quantum had to be determined on a reasonable basis rather than by a purely mechanical computation, including where securities were held as stock-in-trade. Intra-organisational interest between head office and foreign branches was treated as a self-to-self transaction, so no taxable income arose and no deduction was allowed. Interest on bad or doubtful debts was governed by the timing rule for taxation, subject to verification and recomputation. Case-Laws Income Tax Fri, 10 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218484