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2022 (8) TMI 380 - AT - Income TaxDisallowance u/s 40(a)(ia) - Addition on account of subscription fee paid - payment made to Deloitte Touche Tohmatsu India Pvt. Ltd. paid under different heads for the reason that these were reimbursement of expenses, hence no TDS was required - CIT (A) was of the opinion that tax is deductible at source in respect of payment of income or other sum comprising an element of income and that reimbursement of expenses cannot partake the nature of income in the hands of the payee of such expenses - HELD THAT:- We find that ld. CIT (A) has passed a reasoned order. His finding of fact that these are reimbursement of expenses which have not been disputed by the Revenue. Hence, in light of case laws referred above, we do not find any need to interfere in the order of ld. CIT (A). Accordingly, we uphold the same. Disallowance of remuneration paid to partners - As submitted that remuneration paid to partners in terms of the partnership deed; that the aggregate of remuneration paid within the limit provided in section 40(b) as concerned partner has confirmed the receipt of remuneration and payment of tax on such remuneration - HELD THAT:- We find that we are in agreement with ld. CIT(A). He has factually examined the issue and given a finding of fact. This finding could not be rebutted by the Revenue. Hence, we uphold the order of ld. CIT (A).
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