S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Testing charges-Not liable to deduct tax at source-Services rendered outside India-Reimbursement expenses-No disallowance could be made-Amendment by Finance Act, 2014, restricting disallowance to 30 per cent of amount paid on which tax had not been deducted at source, will have no retrospective operation-OECD Model Tax Convention, Art 12. [S. 9(1)(vii), 40(a)(i), 195]