No TDS on reimbursement of expenses to Sister concern on Cost basis

ITO Vs Vishinda Diamonds (ITAT Mumbai)

Sister concern made purchases of rough diamonds on behalf of assessee. Sister concern made payment of core service charges to vendor after deducting tax at rate of 15 per cent as per article 13 of the India-UK DTAA. Assessee reimbursed expenses to sister concern. HELD, There was no element of margin or profit or value addition by sister concern, therefore no TDS was required to be made at time of payment by assessee to sister concern. The original payment was made by the sister concern of the asses

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