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TMI Blog2011 (3) TMI 1354X X X X Extracts X X X X X X X X Extracts X X X X ..... he orders of Assessing Officer passed under section 201(1) and 201(1A). The only dispute raised by the revenue in these appeals is whether on the facts and in the circumstances of the case CIT(A) was justified in holding that payment made by the assessee towards insurance premium and guarantee charges were not covered by TDS provisions. Since the dispute raised is identical in all the appeals, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he payments were in the nature of reimbursement of cost and therefore there was no element of income embedded in it and therefore no tax was required to be deducted. The Assessing Officer however rejected the contentions raised and held the assessee in default under section 201(1) and also levied interest under section 201(1A). In appeal CIT(A) held that the payments made by the assessee towards i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... adjudicate the issue relating to mutuality. Both the parties had appealed to the tribunal and the tribunal vide order dated 20-10-2010 in ITA No. 1959 and 1823/M/2007 held that CIT(A) was not justified in not adjudicating the ground relating to non taxability of the payment on account of mutuality. The tribunal also observed that it was for the assessee who was a member of KPMG International to sa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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