https://www.taxtmi.com/caselaws?id=307154 The commentary notes that, for an Indian branch of a bank, expatriate salary expenses incurred wholly for the branch were treated as deductible and section 44C was held inapplicable on the stated facts. It also records that inter-office interest paid to head office and received from other branches was not brought to tax or disallowed where prior decisions had already accepted that treatment under the applicable tax and treaty framework. Deferred bank guarantee commission for the unexpired period was regarded as contingent and not accrued income. The note further states that section 115JB was held inapplicable to banking profits prepared under the Banking Regulation Act, and that the counter guarantee commission transfer pricing adjustment was deleted on TNMM and consistency grounds. en-us Thu, 27 May 2021 00:00:00 +0530 Wed, 22 Mar 2023 20:20:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307154 The commentary notes that, for an Indian branch of a bank, expatriate salary expenses incurred wholly for the branch were treated as deductible and section 44C was held inapplicable on the stated facts. It also records that inter-office interest paid to head office and received from other branches was not brought to tax or disallowed where prior decisions had already accepted that treatment under the applicable tax and treaty framework. Deferred bank guarantee commission for the unexpired period was regarded as contingent and not accrued income. The note further states that section 115JB was held inapplicable to banking profits prepared under the Banking Regulation Act, and that the counter guarantee commission transfer pricing adjustment was deleted on TNMM and consistency grounds. Case-Laws Income Tax Thu, 27 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307154