TDS u/s 195 not deductible as payment to sister concern in USA is purely reimbursement of expense

DCIT Vs Trusted Aerospace Engineering Pvt Ltd (ITAT Chennai) ITAT Chennai held that there is no obligation to deduct tax at source u/s 195 of the Income Tax Act as payment made to sister concern in USA is purely reimbursement of expense and doesn’t involve any element of income. Facts- The sole grievance of the Revenue in this appeal is against order of the Ld.CIT(A) in deleting disallowance made by the ld. Assessing Officer amounting to Rs.4,95,20,000/- u/s.40(a)(ia) of the Act, by overlooking the fact that remittance was made towards fee for technical services chargeable to tax u/s.9((1)(v...