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    <title>2015 (9) TMI 1429 - ITAT MUMBAI</title>
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    <description>Pure reimbursement of expenses under a cost allocation and recharge arrangement does not attract tax deduction at source where the payment contains no income element and is not consideration for carrying out work or rendering services. On that basis, reimbursement of employee costs, rent, corporate recharges and support function expenses was held outside section 194C, and the related disallowance under section 40(a)(ia) was not sustainable. The stated rationale also noted that tax had already been deducted at source by the paying company on third-party payments where required.</description>
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      <description>Pure reimbursement of expenses under a cost allocation and recharge arrangement does not attract tax deduction at source where the payment contains no income element and is not consideration for carrying out work or rendering services. On that basis, reimbursement of employee costs, rent, corporate recharges and support function expenses was held outside section 194C, and the related disallowance under section 40(a)(ia) was not sustainable. The stated rationale also noted that tax had already been deducted at source by the paying company on third-party payments where required.</description>
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      <pubDate>Fri, 04 Sep 2015 00:00:00 +0530</pubDate>
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