https://www.taxtmi.com/caselaws?id=468402 Additional ground and supporting evidence were admitted because the ground raised a question of law and the documents were useful for deciding the amalgamation-related dispute. The section 14A disallowance was restricted to 2% of exempt income, and the ECB-related receipt issue was partly resolved in the assessee's favour by applying earlier rulings on foreign branch receipts. Amalgamation, merger and branch-level expenditure matters were remanded for fresh adjudication where factual verification of invoices and allocation details was required, while the interest adjustment against refund interest was allowed. Revenue's challenge to taxability of head office, Singapore and Hong Kong branch receipts failed because the amounts were treated as internal allocation or reimbursement, not fees for technical services or additional profit attribution. en-us Fri, 05 Jan 2018 00:00:00 +0530 Tue, 05 May 2026 11:11:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468402 Additional ground and supporting evidence were admitted because the ground raised a question of law and the documents were useful for deciding the amalgamation-related dispute. The section 14A disallowance was restricted to 2% of exempt income, and the ECB-related receipt issue was partly resolved in the assessee's favour by applying earlier rulings on foreign branch receipts. Amalgamation, merger and branch-level expenditure matters were remanded for fresh adjudication where factual verification of invoices and allocation details was required, while the interest adjustment against refund interest was allowed. Revenue's challenge to taxability of head office, Singapore and Hong Kong branch receipts failed because the amounts were treated as internal allocation or reimbursement, not fees for technical services or additional profit attribution. Case-Laws Income Tax Fri, 05 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468402