Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
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 allowance of salary expenses paid to expatriate employees, rejecting the revenue's argument under Section 28(iv) of the Income Tax Act that unrecorded expenses should lead to deemed income. The tribunal agreed that since these expenses had already been subjected to tax as salary income in the employees' returns, they did not constitute a benefit under Section 28(iv).
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 allowance of salary expenses paid to expatriate employees, rejecting the revenue's argument under Section 28(iv) of the Income Tax Act that unrecorded expenses should lead to deemed income. The tribunal agreed that since these expenses had already been subjected to tax as salary income in the employees' returns, they did not constitute a benefit under Section 28(iv).
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