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Income Tax - Highlights / Catch Notes

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

Case Laws     Income Tax

November 16, 2022

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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