https://www.taxtmi.com/caselaws?id=218540 Interest paid to a Singapore branch was held not to be disallowable under section 40(a)(i) where the treaty language was treated as materially similar to the earlier Special Bench view on payments to a head office or overseas branch, so the same sum could not also be taxed as interest income in India. Broken period interest on purchase of securities was allowed following the assessee's earlier year decision affirmed by the High Court. Advisory fee or commission for arranging loans was held to accrue in full when the sanction-related services were rendered and the fee was received, because it was a non-refundable one-time receipt with no contractual basis for spreading income over the loan period. The question of possible double taxation of the same advisory fee in a later year was remitted for factual verification. en-us Wed, 08 Aug 2012 00:00:00 +0530 Mon, 19 Nov 2012 13:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218540 Interest paid to a Singapore branch was held not to be disallowable under section 40(a)(i) where the treaty language was treated as materially similar to the earlier Special Bench view on payments to a head office or overseas branch, so the same sum could not also be taxed as interest income in India. Broken period interest on purchase of securities was allowed following the assessee's earlier year decision affirmed by the High Court. Advisory fee or commission for arranging loans was held to accrue in full when the sanction-related services were rendered and the fee was received, because it was a non-refundable one-time receipt with no contractual basis for spreading income over the loan period. The question of possible double taxation of the same advisory fee in a later year was remitted for factual verification. Case-Laws Income Tax Wed, 08 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218540