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2022 (2) TMI 1085 - AT - Income TaxTDS u/s 194C - expenditure for any work or service - Disallowance u/s 40(a)(ia) - whether Payment not for doing any 'work' or for provision of any 'Professional/Technical Service' ? - as per assessee payments were mere reimbursement of actual costs incurred by Equinox Global Services Ltd./I-Flex Solution Ltd. (India) on behalf of the assessee, and thus, do not represent expenditure for any work or service in respect of which tax is deductible as per the provisions of the Act - HELD THAT:- As the facts and circumstances of the present case are similar to the assessment year 2010-11, respectfully following the decision we hold that the nature of payments made by the assessee to I-Flex Solution Ltd. (India) and Equinox Global Services Ltd. are not in the nature as covered under section 194C of the Act and thus there was no liability on the assessee to deduct tax at source on such payments. Accordingly, the order passed by the CIT(A) deleting the disallowance made by the Assessing Officer under section 40(a)(ia) of the Act is affirmed. - Decided in favour of assessee.
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