https://www.taxtmi.com/caselaws?id=70690 The Tribunal allowed the assessee's appeals, holding that payments made to its parent company were reimbursements without a profit element, thus not subject to tax deduction under Section 195. Consequently, disallowance under Section 40(a)(i) was unjustified. The Tribunal also determined that Section 42, a special provision for income computation in the mineral oil business, overrides the general provisions of Section 40(a)(i). The orders of the CIT(A) were set aside, and the additions were deleted. The validity challenge to the notice under Section 148 was abandoned by the assessee. 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 The Tribunal allowed the assessee's appeals, holding that payments made to its parent company were reimbursements without a profit element, thus not subject to tax deduction under Section 195. Consequently, disallowance under Section 40(a)(i) was unjustified. The Tribunal also determined that Section 42, a special provision for income computation in the mineral oil business, overrides the general provisions of Section 40(a)(i). The orders of the CIT(A) were set aside, and the additions were deleted. The validity challenge to the notice under Section 148 was abandoned by the assessee. Case-Laws Income Tax Fri, 20 Feb 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70690