No TDS on Reimbursement of Leased Line Expense to Parent Company

DCIT Vs International Flavours & Fragrances (I) P. Ltd., (ITAT Chennai)

ITAT Chennai ruling on reimbursement of communication expenses to foreign company and managing sales affairs outside India by International Flavours & Fragrances.

Where assessee-company reimbursed community expenses to foreign company for utilising leased lines services situated outside India, said payment not being in nature of ‘royalty’ within meaning of section 9(1)(vi), assessee was not liable to deduct tax at source while making payment in question

FULL TEXT OF THE ITAT JUDGEMENT

These three appeals are filed by the Revenue, aggrieved by the separate orders of the Learned Commissioner of Income Tax (Appeals), Large Taxpayer Unit, Chennai dated 16.01.2014 in

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