TaxTMI 
TaxTMI 
2019 (2) TMI 822
X X X X Extracts X X X X
X X X X Extracts X X X X
....ion 260-A of the Income Tax Act, 1961 challenging judgment of Income-tax Appellate Tribunal (for short "Tribunal"). The appellant Revenue urges following question for our consideration:- "Whether on the facts and the circumstances of the case the ITAT is correct in law in deleting the additions made by the AO in disallowing the reimbursement of the salary and related expenses to the tune of Rs. ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....er of the assessment and resisted such disallowance. The Commissioner of Income Tax [Appeals] ("CIT (A)" for short] allowed the appeal noting that the expenditure related to salary and related expenses were paid to one ITD Cementation India Ltd., towards salary and related expenses in respect of employees deputed to work in the joint venture (assessee). The CIT (A) further noted that the assessee ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... that on such payments, deduction of tax at source was not necessary. The CIT (A) accepted this view. The Tribunal also confirmed the view of the CIT (A) and dismissed Revenue's appeal. 3. Having heard the learned counsel and having perused the documents on record, we see no reason to interfere. The facts on record would suggest that the amount in question was paid by way of reimbursement ....