https://www.taxtmi.com/caselaws?id=795084 MAT provisions under Section 115JA were inapplicable to banking companies before the relevant amendment, based on the established position governing the interaction of income-tax, banking and companies law. Section 44C's restriction on head-office expenditure did not cover salary paid outside India to expatriate employees posted at and serving the Indian branch permanent establishment, because they were not employed in or managing an office outside India. The MAT and expatriate-salary issues therefore did not raise a substantial question of law, while the separate treatment of allocated direct expenses and NRI desk expenses remained 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 MAT provisions under Section 115JA were inapplicable to banking companies before the relevant amendment, based on the established position governing the interaction of income-tax, banking and companies law. Section 44C's restriction on head-office expenditure did not cover salary paid outside India to expatriate employees posted at and serving the Indian branch permanent establishment, because they were not employed in or managing an office outside India. The MAT and expatriate-salary issues therefore did not raise a substantial question of law, while the separate treatment of allocated direct expenses and NRI desk expenses remained for adjudication. Case-Laws Income Tax Wed, 08 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795084