No TDS 194A on Reimbursement of Interest to Parent Company

When the assessee reimburses interest payments to parent company for availing loans under its borrowing facility given by the bank, No TDS obligation arises u/s 194A.  As per the language used by the Parliament what is contemplated is the ‘interest in the form of income’. In the present case the argument of the assessee is that it is only reimbursement of the interest payment in respect of the funds utilised by the assessee towards borrowing facility of it’s parent company. We find that as per the facts on record the assessee company was originally incorporated on 19.06.2003 with the na...