Section 28(iv) Ruling: No Benefit to Korean Company from Non-Reimbursed Salaries Paid by Indian PE, Disallowance Deleted.

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....Addition u/s 28(iv) - salary paid to expatriates - there cannot be a benefit accruing to the Korean company when the Indian PE of the assessee company does not reimburse its Korean company, because the assessee itself is the Korean company and the transaction in question is a wholly non-business and internal transaction of the Korean company - AO directed to delete the impugned disallowance - AT....