https://www.taxtmi.com/highlights?id=99166 Reimbursement of actual staff salary cost from a project office to its head office, with no mark-up, was treated as a payment to self because both formed parts of the same enterprise. On that reasoning, no taxable income arose from the internal allocation, and the amount could not be assessed separately as fees for technical services. The Tribunal followed its earlier view that a transaction between the project office and head office did not generate income in the absence of any element of profit. The addition was deleted for both assessment years. en-us Sat, 25 Apr 2026 08:51:42 +0530 Sat, 25 Apr 2026 08:51:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99166 Reimbursement of actual staff salary cost from a project office to its head office, with no mark-up, was treated as a payment to self because both formed parts of the same enterprise. On that reasoning, no taxable income arose from the internal allocation, and the amount could not be assessed separately as fees for technical services. The Tribunal followed its earlier view that a transaction between the project office and head office did not generate income in the absence of any element of profit. The addition was deleted for both assessment years. Highlights Income Tax Sat, 25 Apr 2026 08:51:42 +0530 https://www.taxtmi.com/highlights?id=99166