KD lite Developers Pvt Ltd v.DCIT, TDS (2024) Chamber’s Journal-December-104 (Mum)(Trib)

S. 194A : Deduction at source-Interest other than interest on securities-No liability on reimbursement of interest paid through group companies which is not constituting income is not liable to deduct tax at source.[S. 201(1), 201(IA)]

Held that reimbursement which not constituting income do not trigger TDS obligation. Accordingly no liability on reimbursement of interest paid through group companies  which is not constituting income is not liable to deduct tax at source, therefore proceedings initiated under sections 201(1) and 201(IA)) are quashed.(AY. 2016-17, 2017-18, 2018-19, 2019-20, 2020-21)   (ITA Nos 5305, 5225, 5354, 5356 & 5357 / Mum/2024 dt 27-11 2024)  

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