2017 (7) TMI 1248

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..... a and Mr.Jas Sanghavi i/b. PDS Legal for the Respondent. PER COURT : 1] We have heard the learned counsel for the Appellant and the learned Senior Counsel for the Respondent. 2] It is fairly submitted by the learned counsel for the Appellant that in respect of the earlier Assessment Years this Court has admitted an appeal in respect of question No.A as framed in the present appeal. The Senior .....

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..... es of the case and in law, the Income Tax Appellate Tribunal was justified in deleting the disallowance of expenditure of Rs. 12,73,34,892/claimed by the assessee as reimbursement of cost of salary and other expenses to its holding company due to nondeduction of TDS under section 40(a)(ia) read with the provisions of the Double Taxation Avoidance Agreement with Singapore." 4] As far as question N .....

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