https://www.taxtmi.com/caselaws?id=468394 The article discusses transfer pricing, branch taxation and deduction issues in a banking group context. It notes that a time-barred transfer pricing order cannot support a TP adjustment, and that bank charges and reimbursements for branch-related support functions were treated as deductible business expenditure rather than disallowable or taxable receipts. It also records that a contingent country-risk provision was not separately deductible, while higher depreciation on motor vehicles was allowed. On treaty-based taxation, the text states that fees for technical services, interest and commission attributable to overseas branches or head office were examined under the applicable DTAA, and that 244A interest and certain commission attribution issues were resolved by applying treaty principles and restricting double taxation. en-us Mon, 10 Mar 2025 00:00:00 +0530 Mon, 04 May 2026 11:35:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468394 The article discusses transfer pricing, branch taxation and deduction issues in a banking group context. It notes that a time-barred transfer pricing order cannot support a TP adjustment, and that bank charges and reimbursements for branch-related support functions were treated as deductible business expenditure rather than disallowable or taxable receipts. It also records that a contingent country-risk provision was not separately deductible, while higher depreciation on motor vehicles was allowed. On treaty-based taxation, the text states that fees for technical services, interest and commission attributable to overseas branches or head office were examined under the applicable DTAA, and that 244A interest and certain commission attribution issues were resolved by applying treaty principles and restricting double taxation. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468394