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ITAT affirmed the appellate order holding that payments made by the assessee to its associated enterprise for reimbursement of seconded employees' salary on a cost-to-cost basis do not constitute taxable fees and therefore do not attract withholding liability under section 195. The Tribunal found no infirmity in the CIT(A)'s reliance on coordinate bench precedent and the jurisdictional High Court decision, upheld the deletion of the addition, and set aside consequential liability and demand framed under sections 201(1) and 201(1A). The Revenue's appeals were dismissed, with no requirement for the assessee to deduct tax at source on such reimbursements.
ITAT affirmed the appellate order holding that payments made by the assessee to its associated enterprise for reimbursement of seconded employees' salary on a cost-to-cost basis do not constitute taxable fees and therefore do not attract withholding liability under section 195. The Tribunal found no infirmity in the CIT(A)'s reliance on coordinate bench precedent and the jurisdictional High Court decision, upheld the deletion of the addition, and set aside consequential liability and demand framed under sections 201(1) and 201(1A). The Revenue's appeals were dismissed, with no requirement for the assessee to deduct tax at source on such reimbursements.
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