Assessee bank claimed expenditure under head ‘NRI Deposit Mobilization’. According to assessee, said amount was expended towards administrative and other related expenses and entire expenditure was for purposes of head office and, therefore, no restrictions in terms of S. 44C could be imposed. Tribunal accepted assessee’s claim. On appeal High court held that in an identical situation for earlier assessment years, revenue had not carried matter due to low tax effect. High Court thus dismissed revenue’s appeal in assessment year in question as well. (AY. 2000-01)
CIT v. Hongkong and Shanghai Banking Corpn. Ltd. (2019) 267 Taxman 502 / 111 taxmann.com 284 (Bom.)(HC) Editorial : SLP of revenue is dismissed as the tax effect involved of less than 2 crores, CIT v. Hongkong and Shanghai Banking Corpn. Ltd. (2019) 267 Taxman 501 (SC)
S. 44C : Non-residents-Head office expenditure-Entire expenditure was for purposes of head office-No restrictions in terms could be imposed-Order of Tribunal is affirmed. [S. 260A]