https://www.taxtmi.com/caselaws?id=58522 A non-resident bank's interest on sterling securities kept with the RBI was treated as taxable Indian income because the securities were required for the banking business and the interest was attributable to the Indian permanent establishment. The treaty position on attribution and reasonable head office expense allocation prevailed over the domestic restriction in section 44C, while related interest deduction required proportionate computation. Payments to charitable trusts were not fully allowable as business expenditure absent proof of business nexus. Disallowances under sections 40A(5) and 37(2A) were deleted, but the levy of interest under sections 139(8) and 217(1A) was held not appealable on merits. The car-loss computation was remanded for fresh determination. en-us Mon, 31 Jul 1989 00:00:00 +0530 Mon, 20 Dec 2010 13:42:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58522 A non-resident bank's interest on sterling securities kept with the RBI was treated as taxable Indian income because the securities were required for the banking business and the interest was attributable to the Indian permanent establishment. The treaty position on attribution and reasonable head office expense allocation prevailed over the domestic restriction in section 44C, while related interest deduction required proportionate computation. Payments to charitable trusts were not fully allowable as business expenditure absent proof of business nexus. Disallowances under sections 40A(5) and 37(2A) were deleted, but the levy of interest under sections 139(8) and 217(1A) was held not appealable on merits. The car-loss computation was remanded for fresh determination. Case-Laws Income Tax Mon, 31 Jul 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58522