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Cost allocation between group companies without any markup is reimbursement of expense not liable for TDS
Case Law Details
- Case Name
- Ray + Keshavan Design Associates Pvt. Ltd Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2011-12
- Courts
- All ITAT, ITAT Bangalore
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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 filed by the assessee, it was observed that, the payment was made as annual charges against invoices raised for usage of Micros...
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