S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Salary-Order giving effect to the order of Tribunal-Once Tribunal had accorded relief to assessee on account of payment of salary to expatriate employees in foreign currency and outside India, deduction was liable to be allowed by Assessing Officer-DTAA-India-Japan.[S. 254(1, Art. 7, Art. 226]
MUFG Bank Ltd v.ACIT (2024)300 Taxman 424 (Delhi)(HC)