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2021 (10) TMI 463 - HC - Income TaxDenying deduction of expatriate costs u/s 37[1] - agreement between the assessee and the employees wherein it was agreed that the income tax liability on the salary to be paid to the employees, shall be borne by the assessee-company but no such contractual liability has been established by the assessee in the present case - HELD THAT:- As the matter requires re-consideration by the Assessing Officer in the light of the ruling of this Court in M/s Rambus Chip Technologies [India] Pvt. Ltd. [2018 (7) TMI 2215 - KARNATAKA HIGH COURT] - More particularly, in the orders impugned, no adjudication is made on the aspect of any existing contractual liability between the assessee and its employees inasmuch as the income tax liability. Hence, setting aside the impugned order, we restore the matter to the file of the Assessing Officer to re-consider the matter sans answering the substantial questions of law raised herein.
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