Payments made as reimbursement towards shared technology services not subject to TDS u/s 195

Brief of the case:

The ITAT Kolkata in the case of M/s AT & S India P. Ltd. held that the reimbursement made to holding co. by its subsidiary towards the share technology services is not taxable in the hands of receiving co. (holding co.) because the reimbursement is not an income for the holding co. and, therefore, such payments made by assessee are not subject to TDS provisions u/s 195 of the Act.
Facts of the case:

• The assessee is a privat

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