https://www.taxtmi.com/caselaws?id=759586 Expenditure incurred abroad to mobilise FCNR deposits for Indian branches was treated as business-procurement cost directed to the Indian establishment, not executive or general administration expenditure under section 44C, so it was allowable on actual basis. Commission earned on credit cards issued by foreign branches and used in India was held not to arise or accrue in India because the facility was extended abroad, the debt arose outside India, and the foreign branch received the commission overseas. On both substantive questions, the view favourable to the assessee was sustained, and the appeals on merits failed. en-us Thu, 19 Sep 2024 00:00:00 +0530 Mon, 04 Aug 2025 18:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759586 Expenditure incurred abroad to mobilise FCNR deposits for Indian branches was treated as business-procurement cost directed to the Indian establishment, not executive or general administration expenditure under section 44C, so it was allowable on actual basis. Commission earned on credit cards issued by foreign branches and used in India was held not to arise or accrue in India because the facility was extended abroad, the debt arose outside India, and the foreign branch received the commission overseas. On both substantive questions, the view favourable to the assessee was sustained, and the appeals on merits failed. Case-Laws Income Tax Thu, 19 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759586