https://www.taxtmi.com/caselaws?id=793400 Interest between an Indian branch and its head office or overseas branches is treated as an internal payment to self and falls outside the applicable deeming fiction; treaty separate-enterprise rules concern profit attribution, not a charging provision. Directly attributable hub-service charges and expatriate salary costs are distinguished from general head-office overheads and are allowable as business expenditure rather than subject to section 44C limits. Broken-period interest on banking securities, mark-to-market losses on outstanding forward contracts, and diminution in current investment values are treated as deductible revenue or business losses where supported by banking operations, consistent accounting treatment and recognised valuation principles. Section 14A does not produce a disallowance where the relevant head-office interest is non-taxable on the stated facts. en-us Fri, 12 Jun 2026 00:00:00 +0530 Mon, 15 Jun 2026 13:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793400 Interest between an Indian branch and its head office or overseas branches is treated as an internal payment to self and falls outside the applicable deeming fiction; treaty separate-enterprise rules concern profit attribution, not a charging provision. Directly attributable hub-service charges and expatriate salary costs are distinguished from general head-office overheads and are allowable as business expenditure rather than subject to section 44C limits. Broken-period interest on banking securities, mark-to-market losses on outstanding forward contracts, and diminution in current investment values are treated as deductible revenue or business losses where supported by banking operations, consistent accounting treatment and recognised valuation principles. Section 14A does not produce a disallowance where the relevant head-office interest is non-taxable on the stated facts. Case-Laws Income Tax Fri, 12 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793400