Tag Archives: Assistant Director of Income-tax

Inter-office service charges, expatriate CEO salary, and repo interest are deductible, while specific transfer pricing comparables and adjustments require verification.

By | November 5, 2026
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Inter-office service charges, expatriate CEO salary, and repo interest are deductible, while specific transfer pricing comparables and adjustments require verification. Issue Whether inter-office service charges between a foreign bank’s head office and its Indian branch are taxable, whether expatriate CEO salary paid directly by the head office is restricted under section 44C or deductible under… Read More »

Settlement Commission Cannot Grant Immunity to Pre-Initiated Prosecutions, But Prolonged Criminal Proceedings Are Liable to Quashing

By | October 15, 2026
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Settlement Commission Cannot Grant Immunity to Pre-Initiated Prosecutions, But Prolonged Criminal Proceedings Are Liable to Quashing Issue Whether the Settlement Commission has statutory jurisdiction under Section 245H to grant immunity from prosecution if criminal proceedings were already initiated before the filing of a settlement application under Section 245C. Whether ongoing criminal prosecution under Section 277… Read More »

State-governed charitable trust is entitled to exemption as fund transfer for hazard mitigation equipment does not violate section 13.

By | July 6, 2026
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State-governed charitable trust is entitled to exemption as fund transfer for hazard mitigation equipment does not violate section 13. Issue Whether the appellant-trust, formed by the State Government for disaster mitigation, is entitled to tax exemption under Section 11 when its interest income was spent on purchasing high-end hazard mitigation computing equipment in the name… Read More »

Mandatory Contractual Site Restoration Provisions Are Fully Deductible and Cannot Be Added Back to Book Profits

By | June 27, 2026
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Mandatory Contractual Site Restoration Provisions Are Fully Deductible and Cannot Be Added Back to Book Profits Issue Whether a provision for site restoration expenses made pursuant to a mandatory contract with the Government of India is allowable as a business deduction under Section 37(1) of the Income-tax Act, 1961. Whether such a provision constitutes an… Read More »