2019 (2) TMI 1638

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... for the Respondent. P.C:­ The Revenue is in Appeal against the Judgment of the Income Tax Appellate Tribunal (in short "the Tribunal"), raising the following questions for our consideration:­ " Whether on the facts and in the circumstances of the case and in law, the Tribunal erred in deleting the disallowance u/s. 40(a)(ia) on account of non deduction of tax at sources on account o .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ble to dislodge these findings of fact recorded by the Tribunal. That being the position, we must proceed on the basis that the payment in question was in the nature of reimbursement of costs. As held by the Supreme Court in the case of Director of Income Tax v/s. A. P. Moller Maersk A. S. reported in 78 taxmann.com 287 and consistently followed by this Court in the number of decisions, liability .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X