Salaries paid by foreign company to its expatriates working in Indian branch office held to be allowable

Facts A T Kearney Ltd., UK (assessee), a company engaged in the business of providing management consulting services, carried on its business operations in India through its branch office . The assessee deputed highly experienced personnel to train and develop the local expertise to provide services to Indian clients in line with its global standards. The expatriate employees continued to draw their salaries from the overseas office. In computing the total income of the branch office (being treated as a permanent establishment of the assessee), the assessee claimed deduction for the salary pa...