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2018 (6) TMI 839 - ITAT MUMBAIDisallowance of 50% of management charges u/s 44C - treatment as Head Office expenditure - Held that:- While deciding identical issue in case of assessee’s Group Company M/s. Lloyd’s Register Asia (India Branch Office), in AY 2005–06, the Tribunal [2015 (6) TMI 423 - ITAT MUMBAI] has held that management charges paid to the Head Office do not come within the purview of section 44C - thus following the aforesaid decision of the Co–ordinate Bench, we delete the 50% disallowance made out of management charges u/s 44C - Decided in favor of assessee. Applicability of 40(a)(i) on payment of management charges - Held that:- Following the judgement of decision of the Hon'ble Delhi High Court in CIT v/s Herbalife India International Pvt. Ltd. [2016 (5) TMI 697 - DELHI HIGH COURT] it is held that provisions of section 40(a)(i) of the Act are not applicable to payment of management charges - Decided in favour of the assessee. No interest under section 234B of the Act is chargeable - Decided in favour of the assessee.
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