https://www.taxtmi.com/caselaws?id=751556 ITAT Mumbai ruled in favor of the assessee on multiple grounds. The tribunal allowed deduction of HO expenses for expatriate employee salaries, following precedent from A.Y. 2001-02. Interest paid to HO was held deductible under DTAA provisions, citing Sumitomo Mitsui Banking Corporation decision. Refurbishment expenses were treated as revenue expenditure since assets belonged to landlord. TP adjustment was partially allowed after directing AO to verify CPA certificates and allocation keys. Section 14A disallowance was restricted to 1% of exempt income. Premium on retail asset portfolio acquisition was allowed as deferred revenue expenditure over 5 years. HO expenditure deduction was permitted under Article 26 of tax treaty without section 44C restrictions. en-us Fri, 15 Mar 2024 00:00:00 +0530 Thu, 18 Apr 2024 08:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751556 ITAT Mumbai ruled in favor of the assessee on multiple grounds. The tribunal allowed deduction of HO expenses for expatriate employee salaries, following precedent from A.Y. 2001-02. Interest paid to HO was held deductible under DTAA provisions, citing Sumitomo Mitsui Banking Corporation decision. Refurbishment expenses were treated as revenue expenditure since assets belonged to landlord. TP adjustment was partially allowed after directing AO to verify CPA certificates and allocation keys. Section 14A disallowance was restricted to 1% of exempt income. Premium on retail asset portfolio acquisition was allowed as deferred revenue expenditure over 5 years. HO expenditure deduction was permitted under Article 26 of tax treaty without section 44C restrictions. Case-Laws Income Tax Fri, 15 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751556