Court held that , when no composite bills are issued but separate bills are issued towards reimbursement of transportation charges, Circular No. 715 ([1995] 215 ITR (St.) 12) is not applicable.  When reimbursement of  expenses  are made  n income arises  hence tax not deductible at  source .   Accordingly unless the paid amount has any “income element” in it, there will arise no liability to pay any Income-tax upon such amount. The liability to deduct or collect Income-tax at source is upon “such income” as referred to in section 190(1) of the Income-tax Act, 1961 . The expression “such income” would ordinarily relate to any amount which has an “income element ” in it and not otherwise.