Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2015 (6) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2015 (6) TMI 680 - HC - Income TaxDisallowance under Section 40(a)(ia) - rent payment made without deduction of TDS - ITAT deleted the addition - Held that:- Commissioner of Income Tax (Appeals) as well as the Tribunal has reached a concurrent finding of fact that the payment made by the respondent assessee to its holding company of ₹ 51.91 lacs is not rent but is merely a reimbursement of expenses. Consequently, the occasion to apply Section 195 of the Act does not arise. This concurrent finding of fact is not shown to be perverse. Thus, no substantial question of law arises for our consideration and the appeal seeks to challenge concurrent findings of fact. - Decided against revenue.
|