https://www.taxtmi.com/caselaws?id=246764 Deductibility of head office expenditure for expatriate staff under section 44C depended on the statutory conditions and the business purpose of the expense, not on the absence of a debit note or accounting entry in the branch books, and the claim was allowed. Interest remitted by the Indian branch to its overseas head office was treated as not attracting withholding under section 195 in the relevant context, so the disallowance under section 40(a)(ia) failed. A delay in filing the appeal was condoned on a liberal reading of sufficient cause, the explanation being accepted as bona fide and substantial justice preferred over technical delay. en-us Wed, 26 Mar 2014 00:00:00 +0530 Fri, 26 Aug 2022 09:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=246764 Deductibility of head office expenditure for expatriate staff under section 44C depended on the statutory conditions and the business purpose of the expense, not on the absence of a debit note or accounting entry in the branch books, and the claim was allowed. Interest remitted by the Indian branch to its overseas head office was treated as not attracting withholding under section 195 in the relevant context, so the disallowance under section 40(a)(ia) failed. A delay in filing the appeal was condoned on a liberal reading of sufficient cause, the explanation being accepted as bona fide and substantial justice preferred over technical delay. Case-Laws Income Tax Wed, 26 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=246764