INCOME TAX ACT, 1961

Section 37(1)

Business expenditure - Allowability - Salary paid by HO (Japan) to expatriate employees working in India -

Head office of assessee was situated in Japan and deputed certain employees to work in its branches situated in India. Issue was as regards validity of disallowance of salary paid to overseas expatriates of assessee working in India by Head Office (HO) and Indian taxes paid thereon by the head office. Held: In absence of any change in the facts and circumstances of the case, following decision of High Court and subsequently followed by the Coordinate Benches for assessment year 2013-14, AO was directed to delete the disallowance of salary paid overseas to the expatriates of assessee working in India by the head office and the Indian taxes paid thereon by that office.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2015-16

INCOME TAX ACT, 1961

Section 14A

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