ITAT held that recurring issues between the assessee and the Revenue are resolved in the assessee's favor: expenses for salaries paid overseas to expatriates were held to be incurred wholly and exclusively by the Indian branch and not allocable to the HO or other branches, and the tribunal reversed the lower authorities' treatment. The tribunal further held that Section 115JB (MAT) was not applicable because the profit and loss account was not prepared under Part II of Schedule VI and banking companies' special accounting regimes precluded retrospective application of Section 115JB. Interest income received by the Indian branch from the HO/overseas branches was held not taxable in the assessee's hands.
ITAT held that recurring issues between the assessee and the Revenue are resolved in the assessee's favor: expenses for salaries paid overseas to expatriates were held to be incurred wholly and exclusively by the Indian branch and not allocable to the HO or other branches, and the tribunal reversed the lower authorities' treatment. The tribunal further held that Section 115JB (MAT) was not applicable because the profit and loss account was not prepared under Part II of Schedule VI and banking companies' special accounting regimes precluded retrospective application of Section 115JB. Interest income received by the Indian branch from the HO/overseas branches was held not taxable in the assessee's hands.
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