TDS disallowance and India-UK Treaty reimbursement treatment were treated as settled in favour of the assessee.

Disallowance under section 40(a)(i) for failure to deduct tax at source under section 195, and the treatment of salary reimbursements and other expenditure under Article 13 of the India-UK Treaty, are the central issues discussed. The text states that these questions had already been answered in favour of the assessee by an earlier judgment, so the substantive questions were treated as concluded against the revenue. The limitation objection was not decided and was left open.

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Issues: Whether the disallowance under section 40(a)(i) of the Income-tax Act, 1961 for non-deduction of tax at source under section 195, and the treatment of reimbursement of salary costs and other expenditure under Article 13 of the India-UK Treaty, were liable to be decided in favour of the revenue or the assessee.

Analysis: The questions raised in the revenue's appeal were found to have already been answered in favour of the assessee by an earlier judgment. On that basis, the Court treated the substantial questions of law as concluded against the revenue. The objection regarding limitation was not decided and was kept open.

Conclusion: The substantial questions of law were answered in favour of the assessee and against the revenue.

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