https://www.taxtmi.com/caselaws?id=236152 Section 14A disallowance does not survive where the related NOSTRO interest income is itself taxed, and earlier interest and administrative expenses were therefore consequentially deleted. Receipts of interest and commission from head office and branches were sustained as taxable, while the corresponding outgo was allowed to the extent properly disallowed, with the additional double-taxation addition deleted. The India-France treaty non-discrimination clause was held not to bar the higher rate applicable to non-resident companies because the compared entities were not operating in the same conditions. Data processing charges paid to head office were remanded for fresh examination on the royalty issue, and provisions written back were not taxable again where they had already been brought to tax in earlier years. en-us Wed, 07 Aug 2013 00:00:00 +0530 Fri, 16 Aug 2013 09:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236152 Section 14A disallowance does not survive where the related NOSTRO interest income is itself taxed, and earlier interest and administrative expenses were therefore consequentially deleted. Receipts of interest and commission from head office and branches were sustained as taxable, while the corresponding outgo was allowed to the extent properly disallowed, with the additional double-taxation addition deleted. The India-France treaty non-discrimination clause was held not to bar the higher rate applicable to non-resident companies because the compared entities were not operating in the same conditions. Data processing charges paid to head office were remanded for fresh examination on the royalty issue, and provisions written back were not taxable again where they had already been brought to tax in earlier years. Case-Laws Income Tax Wed, 07 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236152