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Applicability of TDS on salary to employee) deputed by the Foreign Co in relation to work of Indian Subsidiary, which is reimbursed on cost to cost basis
Salary cost of employees (onshore and offshore) deputed by the Foreign Co in relation to work of Indian Subsidiary, which is reimbursed on cost to cost basis, is not subject to TDS u/s 195 in the absence of income element.
It has been held that, AO cannot make ad-hoc disallowance of expenses for want of supportings for each expense, without pointing defect in vouchers on sample basis furnished by the Assessee
The copy of the order is as under: