Daily Archives: July 30, 2026

Interest from Head Office, Hub Costs, Broken-Period Interest, Salary Reimbursements, MTM Losses, and Securities Diminution Are Allowable

By | July 30, 2026
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Interest from Head Office, Hub Costs, Broken-Period Interest, Salary Reimbursements, MTM Losses, and Securities Diminution Are Allowable Issue Whether interest credited to an Indian Permanent Establishment (PE) branch by its foreign Head Office/overseas branches is taxable in India under Section 9 read with Article 7 of the India-USA DTAA. Whether centralized operational hub expenses paid… Read More »

Disallowance of Intangible Asset Depreciation on Opening WDV, Unearned Advance Subscription Revenue, and Interest on Inherited Slump-Sale Borrowings Is Impermissible Without Rebuttal or Finding of Unreasonableness

By | July 30, 2026
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Disallowance of Intangible Asset Depreciation on Opening WDV, Unearned Advance Subscription Revenue, and Interest on Inherited Slump-Sale Borrowings Is Impermissible Without Rebuttal or Finding of Unreasonableness Disallowance of Intangible Asset Depreciation on Opening WDV, Unearned Advance Subscription Revenue, and Interest on Inherited Slump-Sale Borrowings Is Impermissible Without Rebuttal or Finding of Unreasonableness Issue Whether depreciation… Read More »

Once Form 2 Is Issued Under VSVS, CIT(A) Cannot Remand Assessment; Proceedings Stand Settled Conclusively

By | July 30, 2026
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Once Form 2 Is Issued Under VSVS, CIT(A) Cannot Remand Assessment; Proceedings Stand Settled Conclusively Issue Whether the CIT(A)/NFAC and Tribunal erred in deciding and remanding an appeal when a declaration under the Direct Tax Vivad se Vishwas Scheme, 2024 had already been accepted with Form No. 2 issued and full payment made. Facts Pendency… Read More »

Company Performing Broader Auto-Component Manufacturing Functions Is a Valid Transfer Pricing Comparable Under TNMM

By | July 30, 2026
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Company Performing Broader Auto-Component Manufacturing Functions Is a Valid Transfer Pricing Comparable Under TNMM Issue Whether a company performing broader auto-component manufacturing functions can be selected as a valid comparable under the Transactional Net Margin Method (TNMM), especially when accepted in subsequent assessment years. Whether the Assessing Officer (AO) is required to grant set-off of… Read More »