Section 14A does not apply to non-income receipts governed by the doctrine of mutuality.
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 »