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2010 (2) TMI 93 - HC - Income TaxSpecial Deduction and Business Expenditure under section 80HHE, 40(a) Technical Services The assessee entered into an agreement with KBS, a company based in Ireland, which required the services of software professional towards the fulfillment of its ongoing activities. Under the terms of the agreement, the assessee was to provide through its consultants, software professionals to render services to KBS. In this case Bombay High Court held that the assessee met the requirement of section 80HHE and the tribunal had correctly held that these amounts constituted only reimbursement of for the expenses incurred by the employees at a particular amount and would not form part of the salary in the hands of the recipients. Hence the question of applying section 40(a)(iii) would not arise and the amount paid by the assessee is allowable for deduction. The appeals are accordingly dismissed. Decision in favor of assessee against the revenue
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