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    <title>2003 (8) TMI 174 - ITAT DELHI-A</title>
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    <description>Marketable securities and UTI units traded through Bankers&#039; Receipts without actual delivery were treated as speculative transactions within section 43(5), so the resulting loss was confined to set-off against speculation profits and not normal banking income. The Portfolio Management Scheme was described as an agency-style investment service, but the impugned addition could not stand because the amount was not debited to profit and loss account or claimed as a deduction, and the excess payment came from the PMS corpus itself. Salary paid outside India to expatriate employees for services rendered in India was disallowable under section 40(a)(iii), and later tax remittance did not cure the disallowance.</description>
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    <pubDate>Fri, 29 Aug 2003 00:00:00 +0530</pubDate>
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      <title>2003 (8) TMI 174 - ITAT DELHI-A</title>
      <link>https://www.taxtmi.com/caselaws?id=63031</link>
      <description>Marketable securities and UTI units traded through Bankers&#039; Receipts without actual delivery were treated as speculative transactions within section 43(5), so the resulting loss was confined to set-off against speculation profits and not normal banking income. The Portfolio Management Scheme was described as an agency-style investment service, but the impugned addition could not stand because the amount was not debited to profit and loss account or claimed as a deduction, and the excess payment came from the PMS corpus itself. Salary paid outside India to expatriate employees for services rendered in India was disallowable under section 40(a)(iii), and later tax remittance did not cure the disallowance.</description>
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      <pubDate>Fri, 29 Aug 2003 00:00:00 +0530</pubDate>
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