https://www.taxtmi.com/caselaws?id=762667 ITAT Mumbai ruled in favor of the assessee regarding TDS liability under section 194A. The assessee argued that interest payments to group entities were reimbursements rather than income subject to TDS. The tribunal found that the assessee borrowed through group entities who obtained bank loans, and the interest payments were merely reimbursements of actual bank interest costs. Since the group entities were not in the lending business and the payments constituted reimbursements rather than income, no TDS obligation arose under section 194A. Consequently, no interest liability under section 201(1A) applied. en-us Wed, 27 Nov 2024 00:00:00 +0530 Thu, 05 Dec 2024 08:37:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762667 ITAT Mumbai ruled in favor of the assessee regarding TDS liability under section 194A. The assessee argued that interest payments to group entities were reimbursements rather than income subject to TDS. The tribunal found that the assessee borrowed through group entities who obtained bank loans, and the interest payments were merely reimbursements of actual bank interest costs. Since the group entities were not in the lending business and the payments constituted reimbursements rather than income, no TDS obligation arose under section 194A. Consequently, no interest liability under section 201(1A) applied. Case-Laws Income Tax Wed, 27 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762667