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2019 (5) TMI 1257 - AT - Income TaxTDS u/s 194C - amount reimbursed towards advertisement expenditure incurred by the distributors - disallowance made u/s 40(a)(ia) - HELD THAT - We are of the considered opinion that the payments made by the appellants to its regional distributors are nothing but reimbursement of expenses. However in the interest of justice and fair play we deem it fit to restore this issue to the file of the Assessing Officer. The assessee is directed to furnish all the invoices raised by its regional distributor on the basis of which it has made payment of Rs. 15.93 crores as reimbursement. AO is directed to verify the invoice and decide the issue whether the impugned payments are reimbursements or not. We would like to make it clear that after verification the Assessing Officer is free to make any enquiry he deems it fit to be made in the hands of the regional distributor as per the provisions of law. - Appeal filed by the assessee is allowed for statistical purposes.
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