https://www.taxtmi.com/caselaws?id=205744 Commission income from a foreign sales order was required to be attributed on the basis of the real functions performed by the head office and the Indian branch, and the assessee's 60:40 allocation was accepted because the head office carried out the substantive contract negotiations while the branch mainly provided support services. Amounts already offered to tax in earlier assessment years could not be taxed again in the year under appeal; only the sum actually received in the relevant year and not previously assessed remained taxable. The claim for head office expenses under section 44C required fresh examination on remand after giving the assessee an opportunity of hearing. en-us Fri, 26 Oct 2007 00:00:00 +0530 Wed, 21 Sep 2011 10:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205744 Commission income from a foreign sales order was required to be attributed on the basis of the real functions performed by the head office and the Indian branch, and the assessee's 60:40 allocation was accepted because the head office carried out the substantive contract negotiations while the branch mainly provided support services. Amounts already offered to tax in earlier assessment years could not be taxed again in the year under appeal; only the sum actually received in the relevant year and not previously assessed remained taxable. The claim for head office expenses under section 44C required fresh examination on remand after giving the assessee an opportunity of hearing. Case-Laws Income Tax Fri, 26 Oct 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205744