https://www.taxtmi.com/caselaws?id=313467 Disallowance under section 40(a)(i) for non-deduction of tax at source on communication and connectivity charges turned on whether payments to a foreign group entity were mere cost reimbursements or consideration attracting withholding obligations. The appellate order was found insufficiently reasoned because it did not properly address the recorded submissions or explain why the payment was not liable to disallowance. The deletion of the disallowance was therefore set aside and the matter remanded for fresh adjudication on the nature of the payment and the applicability of the provision. The cross-objection seeking an enhanced deduction under section 10A did not survive independently and was dismissed. en-us Fri, 02 Jul 2021 00:00:00 +0530 Tue, 16 Apr 2024 20:37:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313467 Disallowance under section 40(a)(i) for non-deduction of tax at source on communication and connectivity charges turned on whether payments to a foreign group entity were mere cost reimbursements or consideration attracting withholding obligations. The appellate order was found insufficiently reasoned because it did not properly address the recorded submissions or explain why the payment was not liable to disallowance. The deletion of the disallowance was therefore set aside and the matter remanded for fresh adjudication on the nature of the payment and the applicability of the provision. The cross-objection seeking an enhanced deduction under section 10A did not survive independently and was dismissed. Case-Laws Income Tax Fri, 02 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313467