https://www.taxtmi.com/caselaws?id=70690 Pure reimbursement of actual expenditure paid to a non-resident parent company, where the production sharing contract and auditor's certificate showed no profit element, was treated as not chargeable to tax; accordingly, no obligation to deduct tax at source arose under section 195 and disallowance under section 40(a)(i) was not warranted. In mineral oil operations, section 42 was treated as the special computation regime governing income under the contractual arrangement, and that special provision prevailed over the general disallowance rule in section 40(a)(i). The expenditure was therefore allowable and the related additions were deleted. en-us Fri, 20 Feb 2009 00:00:00 +0530 Fri, 27 Oct 2023 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70690 Pure reimbursement of actual expenditure paid to a non-resident parent company, where the production sharing contract and auditor's certificate showed no profit element, was treated as not chargeable to tax; accordingly, no obligation to deduct tax at source arose under section 195 and disallowance under section 40(a)(i) was not warranted. In mineral oil operations, section 42 was treated as the special computation regime governing income under the contractual arrangement, and that special provision prevailed over the general disallowance rule in section 40(a)(i). The expenditure was therefore allowable and the related additions were deleted. Case-Laws Income Tax Fri, 20 Feb 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70690