https://www.taxtmi.com/caselaws?id=326703 Expatriate salaries paid in Japan were treated as wholly attributable to the Indian branch and not allocable to the head office, with section 44C not affecting the position on the facts stated. Interest paid by the Indian branch to the head office was deductible in computing branch profits and did not trigger withholding under section 195; the same reasoning applied to reciprocal interest received from Indian branches. Deferred bank guarantee commission was not taxable in the manner proposed by the Revenue. Section 115JB did not apply to the banking company on the stated facts, as its accounts were not prepared under Part II of Schedule VI and the minimum alternate tax provision was not retrospectively extended. en-us Fri, 08 Apr 2016 00:00:00 +0530 Fri, 22 Apr 2016 08:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326703 Expatriate salaries paid in Japan were treated as wholly attributable to the Indian branch and not allocable to the head office, with section 44C not affecting the position on the facts stated. Interest paid by the Indian branch to the head office was deductible in computing branch profits and did not trigger withholding under section 195; the same reasoning applied to reciprocal interest received from Indian branches. Deferred bank guarantee commission was not taxable in the manner proposed by the Revenue. Section 115JB did not apply to the banking company on the stated facts, as its accounts were not prepared under Part II of Schedule VI and the minimum alternate tax provision was not retrospectively extended. Case-Laws Income Tax Fri, 08 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326703