Tribunal held that training, printing and staff welfare expenses which are reimbursed without any profit element. Receipts not chargeable to tax. Not liable to deduct tax at source referred Article 7 of OECD Model Convention. (AY. 2016-17)
BYK Asia Pacific Pte. Ltd. v. ACIT(IT) (2021) 189 ITD 362 (Pune) (Trib.)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Training, printing and staff welfare expenses-Reimbursement of expenses without any profit element-Receipts not chargeable to tax-Not liable to deduct tax at source-Article 7 of OECD Model Convention-DTAA-India-Singapore. [S. 9(1)(i), 195]