Reimbursement for Mobilization Expenses Not Taxable at Source: Section 195 Does Not Apply, Disallowance u/s 40(a)(i) Overturned.

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....TDS u/s 195 - Disallowance of reimbursement of mobilization and demobilization expenses - there was no legal obligation u/s 195(1) on the assessee to deduct tax at source under section 195(1) of the Act on the reimbursement of mobilization and demobilization cost to the holding company (VOAMC). - the disallowance made u/s 40(a)(i) unsustainable - AT....