Section 14A does not apply to non-income receipts governed by the doctrine of mutuality. Issue Whether Section 14A of the Income-tax Act, 1961 applies to interest receipts from head office/overseas branches that fall outside the definition of ‘income’ under Sections 2(24) and 4 due to the doctrine of mutuality. Facts The assessee, a foreign bank… Read More »
ITAT Rules Indian PE Interest Income, Shared Hub Costs, and MTM Losses Non-Taxable or Deductible ITAT Rules Indian PE Interest Income, Shared Hub Costs, and MTM Losses Non-Taxable or Deductible Issue Whether interest credited by Head Office, shared regional hub expenses, broken period interest, expatriate salary reimbursements, year-end Mark-to-Market (MTM) losses on forex contracts, and… Read More »
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 »