No disallowance u/s. 40(a)(ia) as reimbursement of expense considered as receipts and tax paid thereof

Crisil Limited Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that disallowance under section 40(a)(ia) of the Income Tax Act unjustified when reimbursement of expenses is considered as receipts in total income and tax is paid on the same therefore no disallowance in terms of proviso to section 201.

Facts- In this case original assessment was made u/s.143(3) vide order dated 13/03/2015, wherein, the addition of Rs. 1,07,51,004/- was made u/s.40(a)(ia) of the Act for non-deduction of tax at source for payments made to Crisil Ltd., which was in the nature of reimburse

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