https://www.taxtmi.com/caselaws?id=399779 Amounts incurred wholly and exclusively for Indian business operations by expatriate employees deputed to the permanent establishment were held deductible, and the corresponding restriction under section 44C was not applied. Internal interest credited between the Indian permanent establishment, head office, and overseas branches was treated as a self-payment within the same legal entity and not taxable in India. No disallowance under section 14A was upheld for exempt interest from pass-through certificates held as stock-in-trade, and the counter guarantee commission transfer pricing adjustment was deleted because the bundled transactions had already been accepted at arm's length. Education cess and treaty-rate tax on refund interest were remitted for fresh verification and reconsideration. en-us Fri, 16 Oct 2020 00:00:00 +0530 Tue, 09 Aug 2022 16:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399779 Amounts incurred wholly and exclusively for Indian business operations by expatriate employees deputed to the permanent establishment were held deductible, and the corresponding restriction under section 44C was not applied. Internal interest credited between the Indian permanent establishment, head office, and overseas branches was treated as a self-payment within the same legal entity and not taxable in India. No disallowance under section 14A was upheld for exempt interest from pass-through certificates held as stock-in-trade, and the counter guarantee commission transfer pricing adjustment was deleted because the bundled transactions had already been accepted at arm's length. Education cess and treaty-rate tax on refund interest were remitted for fresh verification and reconsideration. Case-Laws Income Tax Fri, 16 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399779