ACIT v. United India Insurance Co. Ltd. (2018) 67 ITR 191 /195 TTJ 65 (UO) (Chennai)(Trib.)

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident–Reimbursement of expenses–Not liable to deduct tax at sources.

Tribunal held that reimbursement of expenditure incurred by non-resident surveyors who were engaged by assessee to estimate and quantify damages occurred outside country-Entire services of surveyors were rendered outside country, therefore, income of surveyors was not liable for taxation in India in respect of service rendered to assessee. Not liable to deduct tax at source. (AY. 2003-04 to 2010-11)