https://www.taxtmi.com/caselaws?id=426891 Interest payable by an Indian branch to its overseas head office was treated as not taxable in India, so the related withholding disallowance under section 40(a)(i) could not survive; the Tribunal also upheld depreciation on assets already added in earlier years because the claim had been allowed in prior years and no infirmity was shown. By contrast, the transfer pricing disputes on guarantee commission and inter-bank placements required fresh benchmarking on a proper FAR and comparability analysis, and the ad hoc enhancement was not sustained. The taxability and depreciation issues were upheld, while the transfer pricing matters were remanded for de novo examination. en-us Wed, 24 Aug 2022 00:00:00 +0530 Sat, 27 Aug 2022 08:17:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426891 Interest payable by an Indian branch to its overseas head office was treated as not taxable in India, so the related withholding disallowance under section 40(a)(i) could not survive; the Tribunal also upheld depreciation on assets already added in earlier years because the claim had been allowed in prior years and no infirmity was shown. By contrast, the transfer pricing disputes on guarantee commission and inter-bank placements required fresh benchmarking on a proper FAR and comparability analysis, and the ad hoc enhancement was not sustained. The taxability and depreciation issues were upheld, while the transfer pricing matters were remanded for de novo examination. Case-Laws Income Tax Wed, 24 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426891