Samode Group, comprised of diversified business entities, is having its registered office located at Jaipur with various business verticals located at different places within and outside the country. The Board of directo

Samode Group, comprised of diversified business entities, is having its registered office located at Jaipur with various business verticals located at different places within and outside the country. The Board of directors regularly have meetings with the heads of each of the business verticals, along with group Finance Director, Company Secretary, Director Taxation and other senior managers and consultants, for reviewing the business results of each of the units and to sort out the various issues. A meeting of all these heads was scheduled for 30th August, 2019 to discuss the various matters relating to taxation and to ascertain as to filing of the return of income of the group companies for the A.Y. 2019-20. The matters which were scheduled for discussion in this meeting, as listed were as under: (6) The net result of the business carried on by one company of the Samode Group Hotels Ltd., as a branch of Swiss Electronics Pvt. Ltd. of UK, a foreign company, located in Mumbai, for the year ended 31st March, 2019 was a loss of ₹ 150 lakh, arrived at after charge of head office expenses of ₹ 210 lakh so allocated by the foreign company to the Indian branch. Stating the provisions of the Income-tax Act, 1961, compute the income to be declared by the branch of Swiss Electronics Pty. Ltd. in India in its return for the assessment year 2019-20.