https://www.taxtmi.com/caselaws?id=800804 Concessional-rate interest remains taxable income, so related expenditure is not disallowable merely because tax applies at a lower rate. Mutual receipts between an Indian PE and its Head Office or overseas branches are not income, preventing disallowance of connected expenditure. Year-end foreign-exchange forward-contract losses consistently recognised under mercantile accounting are deductible where an existing obligation is reasonably measurable. For exempt-income investments funded from mixed funds, interest-free funds may be presumed used absent a proven borrowing nexus. Broken-period interest and voluntary-retirement payments incurred in ongoing banking business are revenue deductions. Head Office and global-system charges require prior characterisation as qualifying overseas executive or general-administration expenditure before tax treatment is determined. en-us Thu, 08 Oct 2026 00:00:00 +0530 Mon, 12 Oct 2026 04:18:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800804 Concessional-rate interest remains taxable income, so related expenditure is not disallowable merely because tax applies at a lower rate. Mutual receipts between an Indian PE and its Head Office or overseas branches are not income, preventing disallowance of connected expenditure. Year-end foreign-exchange forward-contract losses consistently recognised under mercantile accounting are deductible where an existing obligation is reasonably measurable. For exempt-income investments funded from mixed funds, interest-free funds may be presumed used absent a proven borrowing nexus. Broken-period interest and voluntary-retirement payments incurred in ongoing banking business are revenue deductions. Head Office and global-system charges require prior characterisation as qualifying overseas executive or general-administration expenditure before tax treatment is determined. Case-Laws Income Tax Thu, 08 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800804