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ITAT allowed the assessee's appeal, finding no tax deduction at source (TDS) required for reimbursement expenses to Crisil Limited. The tribunal determined that most payments were business-related and not subject to TDS. A Chartered Accountant's certification in Form 26A confirmed Crisil Limited had included the receipts in its total income, paid appropriate taxes, and filed income returns. Consequently, no disallowance under Section 40(a)(ia) was permissible, with the tribunal specifically noting the service tax component was exempt from TDS per CBDT Circular guidelines. The appeal was consequently allowed in full.
ITAT allowed the assessee's appeal, finding no tax deduction at source (TDS) required for reimbursement expenses to Crisil Limited. The tribunal determined that most payments were business-related and not subject to TDS. A Chartered Accountant's certification in Form 26A confirmed Crisil Limited had included the receipts in its total income, paid appropriate taxes, and filed income returns. Consequently, no disallowance under Section 40(a)(ia) was permissible, with the tribunal specifically noting the service tax component was exempt from TDS per CBDT Circular guidelines. The appeal was consequently allowed in full.
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