https://www.taxtmi.com/caselaws?id=378411 Section 115JA was considered inapplicable to a banking company whose accounts were prepared under the Banking Regulations Act, 1949, because the provision rested on profit and loss accounts drawn up under Schedule VI of the Companies Act, 1956. The article also notes that a treaty-based challenge to section 44C under Article 26 of the India-U.K. DTAA could be admitted and restored for fresh consideration on the existing record, with the Revenue given an opportunity to respond. Expenditure found to relate exclusively to Indian business was treated as outside the head office expense restriction, broken period interest on securities was treated as allowable revenue expenditure, and 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 was considered inapplicable to a banking company whose accounts were prepared under the Banking Regulations Act, 1949, because the provision rested on profit and loss accounts drawn up under Schedule VI of the Companies Act, 1956. The article also notes that a treaty-based challenge to section 44C under Article 26 of the India-U.K. DTAA could be admitted and restored for fresh consideration on the existing record, with the Revenue given an opportunity to respond. Expenditure found to relate exclusively to Indian business was treated as outside the head office expense restriction, broken period interest on securities was treated as allowable revenue expenditure, and 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