Dismissing the appeal the Court held that under section 194D the obligation to deduct is on the person who is paying and the deduction to be made at the time of making such payment. Factually and admittedly no amount had been paid to the agents by the assessee as a reimbursement of expenses incurred by the agent on foreign travel. The assessee had made arrangement for foreign travel for all the agents and paid expenses directly to those service providers. Therefore as no amount was paid to the agents by the respondent, the obligation to deduct Income-tax thereon at source also would  not arise. Referred CIT v. Reliance Life Insurance Co Ltd ( 2019) 414 ITR 551 ( Bom)( HC))