TDS not deductible on Reimbursement without any Profit Element

BYK Asia Pacific Pte. Limited Vs ACIT (ITAT Pune) On going through the documents/material as discussed above, it is evident that Seminar expenses, Training expenses, Printing expenses and Staff welfare expenses are amounts paid by the Indian BO to the Singapore HO, which satisfy the twin conditions of `reimbursement’ as discussed supra, viz., one-to-one direct correlation between the outgo and inflow of the Singapore HO; and the inflow of the identical amount without any profit element. Since the Singapore HO recovered the same amount from the Indian BO as was incurred by it to third parties...