Singapore Office's Cost Recovery from Indian Branch Exempt from TDS u/s 195, No Disallowance per Section 40(a)(i.

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....TDS u/s 195 - Since the Singapore HO recovered the same amount from the Indian BO as was incurred by it to third parties without any profit element, the receipt cannot be construed as “other sum chargeable under the provisions of this Act” so as to warrant deduction of tax at source u/s.195 of the Act by the Indian BO. Once it is held that TDS was not necessary, there can be no question of disallowance u/s.40(a)(i). - AT....