https://www.taxtmi.com/caselaws?id=278640 A pure reimbursement of manpower costs under a secondment arrangement, with no income element in the non-resident's hands, was not subject to withholding tax; the related disallowance under section 40(a)(i) was deleted. Interest disallowance linked to capital work in progress failed because no nexus with borrowed funds was proved and the estimate was unsupported; the deletion was upheld. Recurring software-related payments for annual maintenance, consumables and licence renewals were held to be revenue expenditure because they did not create a new asset or enduring benefit, and that disallowance was also deleted. en-us Tue, 27 Nov 2018 00:00:00 +0530 Fri, 15 Feb 2019 08:05:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=278640 A pure reimbursement of manpower costs under a secondment arrangement, with no income element in the non-resident's hands, was not subject to withholding tax; the related disallowance under section 40(a)(i) was deleted. Interest disallowance linked to capital work in progress failed because no nexus with borrowed funds was proved and the estimate was unsupported; the deletion was upheld. Recurring software-related payments for annual maintenance, consumables and licence renewals were held to be revenue expenditure because they did not create a new asset or enduring benefit, and that disallowance was also deleted. Case-Laws Income Tax Tue, 27 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=278640