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Director of Income Tax (IT) -I Versus M/s. American Express Bank Ltd.

2015 (4) TMI 1041 - BOMBAY HIGH COURT

Deduction of expenses incurred at the head office directly in relation to Indian branches - expenses incurred for solicitation of deposits from NRI I.E. NRI marketing expenses - Non-resident banking company – assessee contended the same to be not cov .....

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is found to be incurred exclusively by H.O. towards the Indian branch, the same is required to be allowed in terms of section 37(1) without any reference to section 44C. See ADIT(I.T.) Vs. Bank of Bahrain & Kuwait (2011 (1) TMI 923 - ITAT, MUMBAI ), .....

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me chargeable at special rate under section 115A ought to be on gross basis and not on net basis did not really arise from the assessment or the assessment order. In that regard we find that the Tribunal in its order particularly at page 102 onwards .....

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found that the assessee in the instant case is carrying on composite business earning incomes which are either not at all chargeable to tax or chargeable to tax at lower rate or chargeable to tax at regular rate. Section 14A has been referred by the .....

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ourse can, therefore, raise any substantial question of law. - Decided against revenue - INCOME TAX APPEAL NO. 1294 OF 2013 - Dated:- 1-4-2015 - S.C. DHARMADHIKARI & A.K. MENON, JJ. Mr. Tejveer Singh for the Appellant. Mr. Percy Pardiwalla, senio .....

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ribunal, one by the Revenue and the other by the assessee. The assessment year was 1997-98. 2. Mr. Tejveer Singh appearing for the Revenue submits that the substantial questions of law are formulated at page 5 of the paper book. 3. However, he fairly .....

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smissed the appeal of the Revenue following the judgment of this Court in the case of Commissioner of Income Tax vs. Emirates Commercial Bank Ltd., 262 ITR 55. 4. He, therefore, submits that Question No.1 can safely be held to be covered against the .....

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rom the assessment or the assessment order. In that regard we find that the Tribunal in its order particularly at page 102 onwards has found that the said question and pertaining to the allowability of expenditure incurred in respect of earning divid .....

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