Held that interest on loans paid to Indian and Foreign banks and payment of legal fees is not liable to deduct tax at source. Disallowance is not justified. (AY. 2009-10 to 2012-13)
Dy. CIT v. CLP India.P. Ltd (2023) 108 ITR 248 (Ahd)(Trib)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Interest-Interest on loans paid to Indian and Foreign banks-Legal fees-Not liable to deduct tax at source-Disallowance is not justified-DTAA-India-USA-Rebate for early payment is not interest-Not liable to deduct tax at source.[S.2(28A), 194A, 195, Art. 12]