https://www.taxtmi.com/caselaws?id=780188 ITAT DELHI - AT held for the assessee that salary paid overseas to expatriates was incurred wholly and exclusively by the Indian branch and not allocable to the Head Office; prior tribunal conclusions rejecting Revenue's identical contentions were affirmed. The tribunal found Section 115JB (MAT) inapplicable because the profit & loss account was not prepared under Part II of Schedule VI and the provision was not retrospective, particularly for entities governed by special banking enactments. The tribunal also reversed lower authorities and held interest income from the Head Office/overseas branches was not taxable in the assessee's hands. en-us Wed, 13 Aug 2025 00:00:00 +0530 Sat, 25 Oct 2025 09:00:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780188 ITAT DELHI - AT held for the assessee that salary paid overseas to expatriates was incurred wholly and exclusively by the Indian branch and not allocable to the Head Office; prior tribunal conclusions rejecting Revenue's identical contentions were affirmed. The tribunal found Section 115JB (MAT) inapplicable because the profit & loss account was not prepared under Part II of Schedule VI and the provision was not retrospective, particularly for entities governed by special banking enactments. The tribunal also reversed lower authorities and held interest income from the Head Office/overseas branches was not taxable in the assessee's hands. Case-Laws Income Tax Wed, 13 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780188