https://www.taxtmi.com/caselaws?id=292005 Reimbursement of data processing cost to the head office was treated as infrastructure cost, not royalty, so no withholding-tax disallowance under section 40(a)(i) arose. Interest paid by the branch to the head office was held not taxable in the head office's hands under the applicable treaty position, and the corresponding claim was allowed in computing branch profits. Disallowance under section 14A read with Rule 8D was also rejected because no exempt-income nexus was established. The additions on all three counts were deleted and the revenue's appeals failed. en-us Thu, 28 Mar 2019 00:00:00 +0530 Thu, 03 Dec 2020 19:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=292005 Reimbursement of data processing cost to the head office was treated as infrastructure cost, not royalty, so no withholding-tax disallowance under section 40(a)(i) arose. Interest paid by the branch to the head office was held not taxable in the head office's hands under the applicable treaty position, and the corresponding claim was allowed in computing branch profits. Disallowance under section 14A read with Rule 8D was also rejected because no exempt-income nexus was established. The additions on all three counts were deleted and the revenue's appeals failed. Case-Laws Income Tax Thu, 28 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=292005