https://www.taxtmi.com/caselaws?id=285912 Interest paid to the head office or overseas branches was allowed as a deduction where the corresponding interest receipt had been brought to tax, despite section 40(a)(i). Under section 14A, no interest disallowance was made, but administrative expenditure was restricted to a modest percentage of exempt income. Profit on revaluation of unmatured forward forex contracts was treated as taxable income. Data processing charges were not accepted as royalty on their face and required fresh examination, including possible treatment as head office expenditure under section 44C. Transfer pricing adjustment for ECB-related services was confined to fee and charges, excluding interest. The non-resident company rate was upheld, and the country-risk and NPA provisions were treated as non-deductible provisions. en-us Fri, 21 Mar 2014 00:00:00 +0530 Mon, 03 Feb 2020 08:37:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285912 Interest paid to the head office or overseas branches was allowed as a deduction where the corresponding interest receipt had been brought to tax, despite section 40(a)(i). Under section 14A, no interest disallowance was made, but administrative expenditure was restricted to a modest percentage of exempt income. Profit on revaluation of unmatured forward forex contracts was treated as taxable income. Data processing charges were not accepted as royalty on their face and required fresh examination, including possible treatment as head office expenditure under section 44C. Transfer pricing adjustment for ECB-related services was confined to fee and charges, excluding interest. The non-resident company rate was upheld, and the country-risk and NPA provisions were treated as non-deductible provisions. Case-Laws Income Tax Fri, 21 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285912