https://www.taxtmi.com/caselaws?id=234223 The Bombay High Court treated the dispute largely as fact-driven: it declined to interfere with the Tribunal's finding that payments to sister concerns were reimbursements of salaries for deputed employees, so Section 40(a)(ia) was not attracted; it also refused to entertain the challenge under Section 36(1)(iii) because the Tribunal found no non-business advances and the assessee had sufficient interest-free funds. The Court further held that the alleged overall tax implication between payer and payee did not arise separately. Only the question whether Section 40(a)(ia) applies to payments for technical and professional services on which tax was deductible under Chapter XVII-B was admitted for further consideration. en-us Thu, 07 Mar 2013 00:00:00 +0530 Mon, 03 Jun 2013 09:05:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234223 The Bombay High Court treated the dispute largely as fact-driven: it declined to interfere with the Tribunal's finding that payments to sister concerns were reimbursements of salaries for deputed employees, so Section 40(a)(ia) was not attracted; it also refused to entertain the challenge under Section 36(1)(iii) because the Tribunal found no non-business advances and the assessee had sufficient interest-free funds. The Court further held that the alleged overall tax implication between payer and payee did not arise separately. Only the question whether Section 40(a)(ia) applies to payments for technical and professional services on which tax was deductible under Chapter XVII-B was admitted for further consideration. Case-Laws Income Tax Thu, 07 Mar 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234223