Home Highlights February 2014 Year 2014 This

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1. Interest paid to the head office of the assessee bank as well as its overseas branches by the Indian branch cannot be taxed in India being payment to self - AT

2. The High Court upheld the Tribunal's decision regarding the allowability of expenses incurred for garnering FCNR deposits to be maintained at the assessee bank's Indian...

3. Interest paid to Head office (Japanese banking company) by assessee (PE-Indian branch) - not chargeable to tax in India. - AT

4. Taxability of interest payable/paid by the Indian branch office to the head office and its other overseas branches - even though the submission of the Revenue that the...

5. The Delhi High Court examined taxability in India of interest received by an Indian Permanent Establishment (PE) from its Head Office/Overseas Branch under the India-US...

6. Taxability of Interest paid by the branch (PE) in India to its parent foreign bank in Japan - Deduction of interest so paid as expenditure - the interest income received...

7. The Appellate Tribunal upheld the validity of the National Faceless Assessment Centre's notice u/s 143(2) for the assessee. Regarding tax rates for domestic companies...

8. Disallowance of interest paid to Head Office - Non deduction of TDS - assessee submitted that Assessing Officer held that interest income is taxable under DTAA at 10% in...

9. Income taxable in India - Taxability of interest paid by the Indian branch office to the other overseas branches of the assessee - the fiction of hypothetical...

10. There is a clear distinction between the NOSTRO interest earned/paid by the assessee from/to its own Head office/overseas branches and NOSTRO interest paid/earned...

11. Levy of service tax - applicability of Reverse Charge Mechanism - Business Auxiliary Service - he services have been provided by the foreign agents to the foreign site...

12. Transfer pricing adjustment - transaction between a head office in a foreign country and its branch office in India - principle of mutuality - it is axiomatic that...

13. Services being provided by the branch office in India to the Head Office in USA - income earned by the assessee from the activities carried on by it is taxable in India - AT

14. Input tax credit on common services - Eligibility of Head Office to avail ITC - in the instant case, it is observed that the common input services received by the...

15. Levy of service tax - applicability of Reverse Charge Mechanism - the services have been provided by the foreign Insurance Company to the foreign site office/branch...