Revenue Authority Cannot Classify Reimbursed Employee Secondment Salary as Non-Deductible Expenditure.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Justification for the expenditure - amount paid towards secondment of employees - The contention of the AO that, real beneficiary of the Australian entity’s employees was not the JV but the AE, rejected. - Revenue is not permitted to hold salary payment reimbursed to AE is a non deductible expenditure.....