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2021 (6) TMI 107 - HC - Income TaxTDS u/s 195 - reimbursement of expenses paid paid to M/s. Cerner Corporation, USA - disallowance under section 40(a)(ia) for non deducting TDS - HELD THAT:- Admittedly, the first substantial question of law has been rendered academic. Therefore, it is not necessary for us to answer the same. However, it is directed that the finding of the Tribunal with regard to the first substantial question of law shall not be treated as a precedent and it shall be open for the parties to argue the same in an appropriate case even in subsequent years. Re-computation of section 10A - HELD THAT:- Insofar as the second substantial question of law is concerned, the same has been answered by the Supreme Court in HCL TECHNOLOGIES [2018 (5) TMI 357 - SUPREME COURT]. Accordingly, the same is answered against the revenue and in favour of the assessee.
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