Allowing the petition the Court held that unless the paid amount has any “income element” in it, there will arise no liability to pay any Income-tax upon such amount. Further, in such a situation, there will also arise no liability of any deduction of tax at source upon such amount. Again, 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. 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.