https://www.taxtmi.com/caselaws?id=796261 Head office expenditure limitation applies only to overseas costs meeting the statutory test of executive and general administration expenditure within specified categories. NRI desk costs were disallowable, while data-processing costs require fresh factual classification. Where interest-free funds exceed exempt-income investments, investments are presumed funded from those sources, so no interest disallowance applies. Provision for bad and doubtful debts must be deducted before computing the head office expenditure deduction. Interest paid by an Indian branch to overseas branches is not taxable in India; therefore, no withholding-based disallowance arises. Tax deducted on such interest may be credited or refunded only to the deductee, not the deductor. en-us Wed, 22 Jul 2026 00:00:00 +0530 Mon, 03 Aug 2026 08:20:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796261 Head office expenditure limitation applies only to overseas costs meeting the statutory test of executive and general administration expenditure within specified categories. NRI desk costs were disallowable, while data-processing costs require fresh factual classification. Where interest-free funds exceed exempt-income investments, investments are presumed funded from those sources, so no interest disallowance applies. Provision for bad and doubtful debts must be deducted before computing the head office expenditure deduction. Interest paid by an Indian branch to overseas branches is not taxable in India; therefore, no withholding-based disallowance arises. Tax deducted on such interest may be credited or refunded only to the deductee, not the deductor. Case-Laws Income Tax Wed, 22 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796261