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Case Law Details

Case Name : Neo Sports Broadcast Pvt.Ltd Vs CIT (TDS) (ITAT Mumbai)
Related Assessment Year : 2010-11, 2011-12
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Brief of the Case

The Subsidiary Co. had mere reimbursed the Bank Gurantee Commission to its holding Co. & there is no money borrowed or debt incurred. Therefore, provisions of sec. 2(28A) and sec. 194A do not apply. Payment made to holding Co. is not “income by way of interest”. The impugned receipt would be in the nature of reimbursement of expenses incurred by it & therefore does not attract TDS provision of Section 194A.

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