The assessees had submitted that the amounts were paid as reimbursement of the exact amount of salary disbursed by the companies, which did not attract the element of income ; that incentive payments were made directly to such employees; and hence, no tax was deducted at source. However no evidence was produced by the assessees to prove that payments made to group companies were reimbursement of actual expenditure and there was no profit element involved in the amount representing incentive paid to the employees. The disallowance under section 40(a)(ia) was justified. The amendment restricting the disallowance to 30 per cent. of the expenditure, came into effect only from April 1, 2015 and the assessment year under consideration was 2012-13 and hence, the amendment was not applicable to the case of the assessee. Accordingly, the alternative plea raised by the assessee was rejected by the Tribunal. The view of the Tribunal was just and proper and needed no interference by the court.(AY.2003-04 to 2014-15)