TDS under Section 195 shall not be subjected to disallowance under S. 40(a)(i): ITAT

Applied Material India Private Limited Vs ACIT (ITAT Bangalore) Conclusion: In present facts of the case, the Hon’ble Tribunal remanded the matter to AO to reconsider disallowance made under Section 40(a)(i) pertaining to whether the assessee has made TDS under section 192 with respect the salary paid to the seconded employees in its entirety. If assessee is able to prove that it had made TDS with regard to the salary payment of the seconded employees in its entirety, the AO shall not make any disallowance under section 40(a)(i) of the Act for non-deduction of tax under section 195 of the Ac...