https://www.taxtmi.com/caselaws?id=473151 Cost-to-cost reimbursement of interest expenditure among group entities does not attract tax deduction at source under section 194A when it contains no income element. Where entities share collectively borrowed funds, allocate third-party interest according to their use, and reimburse the expenditure without markup, the payments represent recovery of expenditure rather than income. Tax is deducted on interest paid to third-party lenders; no default or consequential interest liability arises from the reimbursements. en-us Mon, 09 Dec 2024 00:00:00 +0530 Thu, 05 Nov 2026 18:47:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=473151 Cost-to-cost reimbursement of interest expenditure among group entities does not attract tax deduction at source under section 194A when it contains no income element. Where entities share collectively borrowed funds, allocate third-party interest according to their use, and reimburse the expenditure without markup, the payments represent recovery of expenditure rather than income. Tax is deducted on interest paid to third-party lenders; no default or consequential interest liability arises from the reimbursements. Case-Laws Income Tax Mon, 09 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=473151