Management charges paid to HO do not come within purview of section 44C

Lloyd’s Register Quality Assurance Ltd. Vs DCIT (ITAT Mumbai) Undisputed facts are, the Assessing Officer by treating the management charges as Head Office expenses has restricted the claim of the assessee to 5% of the total adjusted income in terms of section 44C of the Act. Whereas, learned Commissioner (Appeals) relying upon the order passed by him for assessment year 2008–09 and 2010–11, has restricted the disallowance under section 44C of the Act to 50% of the amount paid by the assessee. However, as could be seen from the facts on record, while deciding identical issue in case of a...