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2022 (10) TMI 905 - AT - Income TaxAddition u/s 44DA - activities connected to PO/PE in India - services rendered by the overseas employees of home office of the assessee from Hong Kong for the activities performed for the project CMRL/KMRL - HELD THAT:- On careful examination and consideration of the findings of the ld. CIT (Appeals), the evidences placed on record by the assessee, we do not see any infirmity in the order passed by the ld. CIT (Appeal) in holding that the assessee has rightly offered the OCI as fees for technical services under the provisions of section 115A of the Act and the addition made under section 44DA of the Act is liable to be deleted. Ground raised by the Revenue is rejected. Additional ground of appeal raised by the assessee in its cross objection with respect to allowability of deduction under section 37(1) of the Act pertaining to Education Cess, Senior & Higher Education Cess is concerned, it is the submission of the ld. Counsel that this ground is not pressed.
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