Dismissing the appeal of the revenue the Tribunal held that , reimbursed actual cost incurred by KPMG on various services such as premises taken on rent, communication expenses, office space charges etc., since there was no profit element involved in payments in question, assessee was not required to deduct tax at source while making said payments. ( AY. 2005 -06 to 2006 -07)
DCIT v. KPMG Advisory Services (P.) Ltd. (2018) 168 ITD 34 (Mum) (Trib.)
S.40(a)(ia):Amounts not deductible – Deduction at source -Reimbursement of expenses -Not liable to deduct tax at source- No disallowance can be made for failure to deduct tax at source .[ S. 194I ]