https://www.taxtmi.com/caselaws?id=468436 Interest paid to Head Office and overseas branches, and related bank charges, was held deductible under section 40(a)(i) by following the assessee's own earlier years and the Special Bench ratio. Direct Head Office expenses for credit risk, EDP and system support were allowed under section 37(1) on the same recurring factual basis. Disallowance under section 14A was restricted to 2% of exempt income because Rule 8D did not apply for the year. Netting of interest under sections 244A and 234D was permitted, and interest under section 244A was taxable at the treaty rate. Higher depreciation on motor cars, favourable ECB/branch taxation treatment, the TP adjustment on derivative marketing commission, and the non-application of section 115JB to a banking company were all decided for the assessee; only the non-resident banking company rate issue remained adverse. en-us Mon, 11 Sep 2023 00:00:00 +0530 Wed, 06 May 2026 10:37:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468436 Interest paid to Head Office and overseas branches, and related bank charges, was held deductible under section 40(a)(i) by following the assessee's own earlier years and the Special Bench ratio. Direct Head Office expenses for credit risk, EDP and system support were allowed under section 37(1) on the same recurring factual basis. Disallowance under section 14A was restricted to 2% of exempt income because Rule 8D did not apply for the year. Netting of interest under sections 244A and 234D was permitted, and interest under section 244A was taxable at the treaty rate. Higher depreciation on motor cars, favourable ECB/branch taxation treatment, the TP adjustment on derivative marketing commission, and the non-application of section 115JB to a banking company were all decided for the assessee; only the non-resident banking company rate issue remained adverse. Case-Laws Income Tax Mon, 11 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468436