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

3. 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...

4. 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...

5. 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...

6. 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...

7. 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...

8. 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...

9. 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...

10. 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

11. 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...

12. TP adjustment on account of payment of overseas support fee - The assessee has its head office outside India and the decision, on the basis of which the assessee gets...

13. Attributing income to the PE, under the DTAA - The income to the foreign branch from the credit given to its card holders outside India cannot be taxed in the hands of...

14. Transaction between the head office of the assessee and its branch in India was a transaction between the principal and principal. In law, there cannot be a valid...

15. Import of services - if a branch of an Indian bank is situated abroad, Section 66A does not envisage treating the foreign branch as a separate entity so far as the...