https://www.taxtmi.com/caselaws?id=327003 Management charges could not be subjected to an ad hoc 50% tax attribution as fees for technical services without a proper factual basis showing the nature of the services actually rendered; the matter was remanded for fresh adjudication. Business losses arising from closure of the India branch were held eligible for set-off against other heads of income, as the losses remained connected with the winding-up and earlier business activity. Interest under section 234B was not leviable in view of binding jurisdictional precedent, so the levy was rejected. The cross-appeals were therefore disposed of with relief on the loss set-off and interest issues, and reconsideration on the management-charges issue. en-us Fri, 18 Mar 2016 00:00:00 +0530 Thu, 28 Apr 2016 17:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327003 Management charges could not be subjected to an ad hoc 50% tax attribution as fees for technical services without a proper factual basis showing the nature of the services actually rendered; the matter was remanded for fresh adjudication. Business losses arising from closure of the India branch were held eligible for set-off against other heads of income, as the losses remained connected with the winding-up and earlier business activity. Interest under section 234B was not leviable in view of binding jurisdictional precedent, so the levy was rejected. The cross-appeals were therefore disposed of with relief on the loss set-off and interest issues, and reconsideration on the management-charges issue. Case-Laws Income Tax Fri, 18 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327003