Assessee is  engaged in business of software development services to its US based holding company. During year, Assessing Officer  held  that assessee had not deducted TDS under section 195 on international transaction for payment made on account of data line charges to its holding company. Assessing Officer  made an addition as shortfall of TDS amount on data line charges and further calculated interest under section 201(1)/201(1A) of the Act. On appeal the  Commissioner (Appeals) deleted the addition. Tribunal held that  the  amount paid to holding company was on actual cost basis without any element of markup and was in nature of reimbursement of expenses incurred by way of using network connectivity provided by service provider and, therefore, same was not chargeable to tax on any account. Order of CIT(A) is affirmed. (AY. 2013-14)