https://www.taxtmi.com/caselaws?id=430295 The Tribunal upheld the higher tax rate for the assessee, rejecting the argument for a lower rate under the India-Korea DTAA. It allowed the deduction for salaries paid to expatriates by the Head Office, emphasizing that expenses incurred by the HO for the Indian PE should be considered. Issues regarding deduction under section 44C were remitted for fresh adjudication. The Tribunal deleted the ALP adjustment for interest paid and treated the adjustment for interest received as not pressed. Additional grounds related to section 44C were admitted for fresh adjudication, while cross-objections by the Assessing Officer were dismissed. en-us Wed, 09 Nov 2022 00:00:00 +0530 Mon, 04 May 2026 17:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=430295 The Tribunal upheld the higher tax rate for the assessee, rejecting the argument for a lower rate under the India-Korea DTAA. It allowed the deduction for salaries paid to expatriates by the Head Office, emphasizing that expenses incurred by the HO for the Indian PE should be considered. Issues regarding deduction under section 44C were remitted for fresh adjudication. The Tribunal deleted the ALP adjustment for interest paid and treated the adjustment for interest received as not pressed. Additional grounds related to section 44C were admitted for fresh adjudication, while cross-objections by the Assessing Officer were dismissed. Case-Laws Income Tax Wed, 09 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=430295