Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
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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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