Held that since all details were furnished before the Tribunal, and not before the lower authorities, and since it was imperative to first determine the nature of the expenses before deciding the taxability in the source and residence country, the issue is sent back to the Assessing Officer to cull out all relevant facts relating to the expenses and adjudicate the matter of its taxability in India (AY. 2008-09, 2009-10)
Cadila Pharmaceuticals Ltd. v. ACIT (2024)115 ITR 428/ 162 taxmann.com 229 (Ahd)(Trib)
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Payment of legal professional fees-Additional evidence is filed before the ITAT-Matter remanded. [S.9(1)(vii)]