No TDS On Salaries Reimbursed Under Secondment Agreement

1] We have heard Mr. Pinto appearing on behalf of Revenue in support of this appeal. 2] In paragraphs 4.1 and 4.2 of this memo of appeal, the Revenue says that the facts are as under:- “4.1 The Assessing Officer, from the records noted that the Respondent Company had made payment of a sum of Rs. 4.83 crore, to Marks & Spencer’s PLC London, on which no tax was deducted at Source. The application made by the Respondent company was withdraw without assigning any reasons for the said withdrawal. 4.2 While the Company argued that these payments were merely reimbursement of expenditure, ...