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Addition u/s 28(iv) - salary paid to expatriates - there cannot ...


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

November 16, 2022

Case Laws     Income Tax     AT

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

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