Cost allocation between group companies without any markup is reimbursement of expense not liable for TDS

Ray + Keshavan Design Associates Pvt. Ltd Vs DCIT (ITAT Bangalore)

ITAT Bangalore held that as software is procured from somewhere else and allotted to ground companies including the assesse, such cost allocated without any markup is reimbursement of expense and the same is not liable for TDS under section 195 of the Income Tax Act.

Facts- AO observed that, the assessee reflected ₹ 1,36,405/-as reimbursement to M/s. Brand Union Worldwide Ltd-London. From the details file

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