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Bombay High Court in 428ITR398 held that unless the amount paid has any income element in it there shall arise no liability to pay any income-tax more than any liability to deduct any tax thereon.

In this case, the payer carried with him separate bills for transportation and clearing and forwarding reimbursements. The Board Circular No 715 is also held to have application only in case of composite bills scenario as per High Court

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