https://www.taxtmi.com/caselaws?id=795084 Section 115JA is described as inapplicable to banking companies before the relevant amendment, based on an earlier ruling addressing the interaction of the Income-tax Act, Banking Regulation Act and Companies Act. The notes also distinguish expatriate employees posted at an Indian branch permanent establishment from personnel employed in or managing an office outside India. Accordingly, their salary paid outside India is not characterised as head office expenditure subject to the Section 44C limitation. The material states that questions on MAT and expatriate salary did not raise a substantial question of law, while allocated direct expenses and NRI desk expenses remain for adjudication. en-us Wed, 08 Jul 2026 00:00:00 +0530 Thu, 16 Jul 2026 09:07:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795084 Section 115JA is described as inapplicable to banking companies before the relevant amendment, based on an earlier ruling addressing the interaction of the Income-tax Act, Banking Regulation Act and Companies Act. The notes also distinguish expatriate employees posted at an Indian branch permanent establishment from personnel employed in or managing an office outside India. Accordingly, their salary paid outside India is not characterised as head office expenditure subject to the Section 44C limitation. The material states that questions on MAT and expatriate salary did not raise a substantial question of law, while allocated direct expenses and NRI desk expenses remain for adjudication. Case-Laws Income Tax Wed, 08 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795084