https://www.taxtmi.com/caselaws?id=64600 Where salary paid abroad could not be precisely linked to the Indian permanent establishment because the same technical staff also coordinated work for Pakistan projects, a fair estimate of 50% attribution was sustained as a reasonable allocation of deductible expense. The taxpayer's debit notes and auditor certifications did not effectively rebut the Assessing Officer's finding, so full deduction was denied. The 10% disallowance of staff welfare and miscellaneous expenses was also upheld because it was an estimate based on the material on record and no convincing basis was shown to disturb it. en-us Thu, 05 Nov 1998 00:00:00 +0530 Tue, 08 Feb 2011 18:21:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64600 Where salary paid abroad could not be precisely linked to the Indian permanent establishment because the same technical staff also coordinated work for Pakistan projects, a fair estimate of 50% attribution was sustained as a reasonable allocation of deductible expense. The taxpayer's debit notes and auditor certifications did not effectively rebut the Assessing Officer's finding, so full deduction was denied. The 10% disallowance of staff welfare and miscellaneous expenses was also upheld because it was an estimate based on the material on record and no convincing basis was shown to disturb it. Case-Laws Income Tax Thu, 05 Nov 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64600