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2019 (1) TMI 1417 - HC - Income TaxAddition towards reimbursement of the salary and related expenses u/s 40(a)(ia) - TDS liability - Held that:- The facts on record would suggest that the amount in question was paid by way of reimbursement of expenditure. The employees and personnel deputed by the company giving such workers on loan to the assessee company continued to be the employer, the assessee merely reimbursed the expenditure in terms of salary structure of the employees to the employer company. There was, therefore, no question of deducting tax at source while reimbursing such costs. We notice that the Tribunal by the impugned judgment relied on its decision in case of this very assessee for earlier assessment year. This issue had travelled before this Court in CIT Vs. M/s. ITD CEM India Ltd which was dismissed by the High Court [2017 (9) TMI 740 - BOMBAY HIGH COURT] - No question of law.
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