Dismissing the appeal of the revenue the Court held that ; Since no income was reflected in balance sheet and Profit & Loss account of HSL towards payment made by assessee and it was reimbursement of expenses incurred on cost to cost basis by assessee, it could not be treated as in default  .Court also observed that if there is no income embedded in a payment, then TDS provisions would not apply as TDS is only an alternative method of collection of taxes; reimbursement cannot be deducted out of bill amount for purpose of TDS. Under the circumstances, the assessee falls outside the scope of S. 194J read with S. 200 during the relevant assessment years. Consequently, the provisions of S. 201 and 201(1A) are not attracted..Circular No. 715, dated 3-8-1995(AY. 2008-09 to 2010 -11)