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2023 (10) TMI 560 - DELHI HIGH COURTExpenditure incurred for the Indian business outside India - As per ITAT expenses in issue which were disallowed were attributable to the business in India - HELD THAT:- The statement of the auditor attached to the certificate shows that for the period ending on 31.12.2002, out of the gross receipts the cost directly attributable to India were advisory and business support costs and IT costs, amounting to USD 228,000/- and USD 1,469,000/- respectively. The total of these costs in USD would be 1697000. 4.2 Thus, the cost attributable to India, at the exchange rate of Rs. 48.50 per USD, would amount to Rs. 51,440,312/- for the relevant period. This amount has been certified by KPMG. As noted above, the expenses incurred by the respondent/assessee were solely for the Indian business. Clearly, these expenses do not fall within the ambit of Section 44C, which relates to the deduction of head office expenses in case of non- residents. No substantial question of law.
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