https://www.taxtmi.com/caselaws?id=800805 Broken-period interest on securities held as stock-in-trade is revenue expenditure, while interest disallowance for exempt income requires a proven borrowing-investment nexus. Overseas training of Indian-branch staff falls outside the specified head-office expenditure restriction, and unrealised gains on executory forward contracts lack real-income accrual. Payments between an Indian branch and its head office or overseas branches do not trigger withholding where they are not taxable to the same enterprise. Additional Commissioners are included within the expression Joint Commissioner absent proof of missing Board authorisation. Transfer-pricing analysis may cover permanent-establishment dealings, aggregate closely linked placements, but cannot determine the year of income taxability. Integrated correspondent banking and incidental oversight are not separately remunerable without a distinct transaction or benefit; profit-split analysis requires allocation by relative functions, assets and risks. en-us Thu, 08 Oct 2026 00:00:00 +0530 Mon, 12 Oct 2026 04:18:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800805 Broken-period interest on securities held as stock-in-trade is revenue expenditure, while interest disallowance for exempt income requires a proven borrowing-investment nexus. Overseas training of Indian-branch staff falls outside the specified head-office expenditure restriction, and unrealised gains on executory forward contracts lack real-income accrual. Payments between an Indian branch and its head office or overseas branches do not trigger withholding where they are not taxable to the same enterprise. Additional Commissioners are included within the expression Joint Commissioner absent proof of missing Board authorisation. Transfer-pricing analysis may cover permanent-establishment dealings, aggregate closely linked placements, but cannot determine the year of income taxability. Integrated correspondent banking and incidental oversight are not separately remunerable without a distinct transaction or benefit; profit-split analysis requires allocation by relative functions, assets and risks. Case-Laws Income Tax Thu, 08 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800805