https://www.taxtmi.com/caselaws?id=178142 Usance interest paid to non-resident suppliers on imported purchases was treated as part of the purchase transaction, so it did not constitute interest for section 195 and no disallowance under section 40(a)(ia) followed. For foreign currency loans to an associated enterprise, LIBOR-based pricing was accepted as the proper arm's length benchmark, not domestic lending rates. ERP-related outgo was split: the software purchase component was capital, while licences, implementation, maintenance and support were revenue expenditure. Treaty relief for foreign tax paid in Brazil was allowed on the tax liability relating to income accrued and offered to tax, not merely on amounts remitted during the year. en-us Wed, 15 Oct 2014 00:00:00 +0530 Fri, 29 Jan 2016 10:17:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178142 Usance interest paid to non-resident suppliers on imported purchases was treated as part of the purchase transaction, so it did not constitute interest for section 195 and no disallowance under section 40(a)(ia) followed. For foreign currency loans to an associated enterprise, LIBOR-based pricing was accepted as the proper arm's length benchmark, not domestic lending rates. ERP-related outgo was split: the software purchase component was capital, while licences, implementation, maintenance and support were revenue expenditure. Treaty relief for foreign tax paid in Brazil was allowed on the tax liability relating to income accrued and offered to tax, not merely on amounts remitted during the year. Case-Laws Income Tax Wed, 15 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178142