https://www.taxtmi.com/caselaws?id=259168 Mutuality was preserved for transactions with members because contributors and participators remained the same class, but receipts from non-members were held taxable. Pure reimbursement was recognised as generally non-income, yet the branch records did not verify the cost allocation, so the claim of no taxable income from recoveries failed and estimation of income at 5% of gross non-member receipts was sustained. The challenge to head office expense restriction under section 44C was rejected on the facts, as the India-level income position was also unverifiable. Interest under section 234B was held not leviable on a non-resident where tax was deductible at source from the payer. en-us Fri, 10 Apr 2015 00:00:00 +0530 Mon, 04 May 2015 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259168 Mutuality was preserved for transactions with members because contributors and participators remained the same class, but receipts from non-members were held taxable. Pure reimbursement was recognised as generally non-income, yet the branch records did not verify the cost allocation, so the claim of no taxable income from recoveries failed and estimation of income at 5% of gross non-member receipts was sustained. The challenge to head office expense restriction under section 44C was rejected on the facts, as the India-level income position was also unverifiable. Interest under section 234B was held not leviable on a non-resident where tax was deductible at source from the payer. Case-Laws Income Tax Fri, 10 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259168