https://www.taxtmi.com/caselaws?id=459522 ITAT Bangalore ruled on multiple issues for the assessee. Sub-contracting expenses were disallowed due to non-deduction of TDS, but tribunal directed AO to avoid double taxation if provisions were reversed in subsequent year. Professional consultancy charges to Korean company were allowed as training services don't constitute technical services under DTAA. Reimbursement of salary costs was allowed following precedent that seconded employees work under assessee's control. Section 10AA deduction computation was decided in assessee's favor requiring proportionate reduction in both numerator and denominator. MAT credit set-off was granted, and assets received free from related party were not taxed separately as already covered under APA arrangements. en-us Thu, 04 Aug 2022 00:00:00 +0530 Tue, 17 Dec 2024 18:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459522 ITAT Bangalore ruled on multiple issues for the assessee. Sub-contracting expenses were disallowed due to non-deduction of TDS, but tribunal directed AO to avoid double taxation if provisions were reversed in subsequent year. Professional consultancy charges to Korean company were allowed as training services don't constitute technical services under DTAA. Reimbursement of salary costs was allowed following precedent that seconded employees work under assessee's control. Section 10AA deduction computation was decided in assessee's favor requiring proportionate reduction in both numerator and denominator. MAT credit set-off was granted, and assets received free from related party were not taxed separately as already covered under APA arrangements. Case-Laws Income Tax Thu, 04 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459522