Intra-entity interest and banking deductions: head office expenses, foreign exchange losses, and securities valuation treated as allowable.

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....In banking-tax matters, intra-entity interest received by an Indian branch from its head office and overseas branches was treated as internal allocation, not real income, because the deeming rule for interest could not be stretched to a transaction with oneself; the addition was deleted. Centralised hub service charges for data processing, monitoring and risk support were held to be direct operational costs, not restricted head office overheads, and the disallowance was deleted. Broken period interest, mark-to-market loss on unmatured forward contracts, and diminution in value of securities held as stock-in-trade were each allowed as revenue deductions. Reimbursement of expatriate salary was also upheld as branch-specific cost, while the exempt-income disallowance ground was dismissed.....