TDS U/s. 194 not applicable on reimbursement of Payment

Advertisement CIT  Vs Kalyani Steels Ltd. (Karnataka High Court) The primary factor to attract section 194J is the ingredient of “income comprised therein”. If no income is reflected in the balance sheet and P & L account of HSL towards the reimbursement charges paid on cost to cost basis by KSL and ML, it ceases to have the character of income. As such, the assessee cannot be treated as the assessee in default in not deducting tax at source under section 194J of the Act. The arguments of the revenue that the fees paid by the assessee is towards technical services is imagin...