https://www.taxtmi.com/caselaws?id=248964 Transfer pricing attribution between a head office and permanent establishment was not contested, while the ECB-related adjustment was confined to fees and charges for services rather than interest on the underlying borrowing; a 20% estimate was retained on that limited base in the absence of comparables. Interest received on Nostro accounts and overseas placements was accepted as taxable, and corresponding interest paid to the head office and overseas branches was allowed as a deduction. Securities valuation-loss write-backs remained taxable, subject to protection against double taxation. The applicable foreign-company tax rate, interest for excess refund, exempt-income disallowance, deferred IMDS expenses and call-placement interest treatment were sustained against the assessee. en-us Mon, 30 Sep 2013 00:00:00 +0530 Tue, 01 Jul 2014 06:23:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248964 Transfer pricing attribution between a head office and permanent establishment was not contested, while the ECB-related adjustment was confined to fees and charges for services rather than interest on the underlying borrowing; a 20% estimate was retained on that limited base in the absence of comparables. Interest received on Nostro accounts and overseas placements was accepted as taxable, and corresponding interest paid to the head office and overseas branches was allowed as a deduction. Securities valuation-loss write-backs remained taxable, subject to protection against double taxation. The applicable foreign-company tax rate, interest for excess refund, exempt-income disallowance, deferred IMDS expenses and call-placement interest treatment were sustained against the assessee. Case-Laws Income Tax Mon, 30 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248964