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2022 (7) TMI 1418 - AT - Income TaxNon-deduction of TDS - Disallowance u/s 40(a)(i) - reimbursement of salary expenses made on behalf of the seconded employees as fee for technical services - HELD THAT:- We note that the evidences filed by assessee has not been considered by the revenue authorities. We therefore remand this issue to the AO to consider the claim in accordance with the decision of M/s. Flipkart Internet Pvt. Ltd. [2022 (6) TMI 1251 - KARNATAKA HIGH COURT] and M/s. Toyota Boshoku Automotive India Pvt. Ltd. [2022 (4) TMI 1443 - ITAT BANGALORE] and Goldman Sachs Services Pvt. Ltd. [2022 (4) TMI 1444 - ITAT BANGALORE] having regard to the evidences filed by the assessee. Needless to say that proper opportunity of being heard must be granted to assessee in accordance with law. Ground raised by assessee stands allowed for statistical purposes.
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