Salary reimbursements paid through an apex cooperative union for...

Salary reimbursements paid through an apex cooperative union for deputed supervisory staff do not require tax deduction at source where the assessee makes no direct salary payment and the remittance contains no service markup. In those circumstances, disallowance for non-deduction of tax under section 40(a)(ia) does not arise. Interest for delayed deposit of TDS under section 201(1A) cannot be disallowed unless it has been claimed as an expenditure deduction. Verification is required where it is unclear whether that interest was claimed; the interest issue is remanded for this factual verification.