Section 40(a)(ia) & 90 of the Income Tax Act, 1961 — DTAA—Expenditure incurred by the assessee on payment of salaries to the employees of its PE in India and payment made to non residents towards operating contract expenditure has to be allowed in full without any disallowance under section 40(a)(ia) — Deputy Director of Income tax vs. Unocol Bharat Ltd [2018] 196 TTJ (Delhi) 646