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1. 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...

2. 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...

3. TDS u/s 195 - TDS on salary as per provisions of section 40(a)(i) - payment made from India to the employees of Head Office - the assessee is not liable to deduct tax 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. 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

6. 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...

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. 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

9. Additions (Benefit) u/s 28(iv) - Expenditure incurred by the HO for salary paid to the expatriate employees for rendering services to PE - The tribunal upheld the...

10. Supply or not - mixed supply or not - Liaison activities between India office and Dubai office - host of activities undertaken by the Appellant at the behest of their...

11. 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...

12. Taxability of salary income earned by non-residents from Indian companies. In this Judgement, it was determined that under Section 9(1)(ii) of the Income Tax Act, salary...

13. Section 44C refers to common head office expenses and cannot encompass the expenses exclusively incurred by the expenses incurred by head office employees exclusively...

14. Denial of Exemption claim on Salary - the salary accrues to the assessee in Japan and the accrued salary is partly delivered by Motorola India in India. Hence, there is...

15. CENVAT Credit - Input Services - services of electricity expenses in connection with their head office - The location of the head office is immaterial so long it is used...