Section 115A of Income Tax Act, 1961—In the instant case, the appeal raises the question with respect to reimbursement of expenses for the travel of technical personnel in pursuance of an agreement with the Kerala State Electricity Board for supply of technical services.

The assessee claimed reimbursement of their travel expenses as a deduction from the technical know-how fees.

Held that—The expenditure incurred is a direct consequence of the agreement for supply of technical services.
This expenditure incurred has a direct nexus with the technical services supplied and deduction thereof is specifically prohibited under sub-section (3) of Section 115A. In such circumstances, we do not see any reason to interfere with the order of the Tribunal. We answer the question of law raised, against the assessee and in favor of the Revenue.[M/S. SNC LAVALIN INC. VERSUS THE ASSISTANT COMMISSIONER OF INCOME TAX, THIRUVANANTHAPURAM] [2018] [7] [ITCD Online] [54] [KERALA HIGH COURT]