https://www.taxtmi.com/caselaws?id=378411 Section 115JA did not apply to a banking company whose accounts were not required to follow Parts II and III of Schedule VI to the Companies Act, 1956. A treaty-based challenge to the head-office expense restriction under section 44C, based on the India-UK tax treaty's non-discrimination provision, was admitted and remanded for fresh consideration because it required no further factual inquiry but had not been raised earlier. Expenditure incurred exclusively for Indian business was not treated as restricted head-office expenditure, while broken-period interest on securities was allowable as revenue expenditure. Guest-house expenditure remained disallowable under section 37(4). en-us Fri, 12 Apr 2019 00:00:00 +0530 Tue, 16 Apr 2019 13:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=378411 Section 115JA did not apply to a banking company whose accounts were not required to follow Parts II and III of Schedule VI to the Companies Act, 1956. A treaty-based challenge to the head-office expense restriction under section 44C, based on the India-UK tax treaty's non-discrimination provision, was admitted and remanded for fresh consideration because it required no further factual inquiry but had not been raised earlier. Expenditure incurred exclusively for Indian business was not treated as restricted head-office expenditure, while broken-period interest on securities was allowable as revenue expenditure. Guest-house expenditure remained disallowable under section 37(4). Case-Laws Income Tax Fri, 12 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=378411