CIT v Bovis Lend Lease (India) (P.) Ltd. IT Appeal Nos. 15 to 22 of 2010; IT Appeal Crob. NoS. 2 to 9 of 2011† [Karnataka High Court] Background: The assessee, a private limited company, carrying on the business of project and construction management entered into a management services agreement LLAH, Singapore. Under the agreement, LLAH was to provide services like administration, personnel, legal, finance and accounting information, marketing support, insurance matters, treasury management and information technology to the assessee. LLAH filed applications under Section 197 of the Act. LLAH furnished copies of the invoices raised by them to the AO. It was contended that the consideration paid under the agreement is by way of reimbursement of actual expanses. The assessing authority issued certificates authorizing the payment without deduction of tax. Later, the Authority issued a notice under Section 201 calling upon the assessee to show cause as to why he should not be treated, as an assessee in default under Section 201(1) and also why interest should not be levied under Section 201 (1A) as the assessee has not deducted tax as required under Section 195(1) of the Act at the time of making a credit entry. The assessing authority held that the intention of the assessee was to get the benefit of LLAH’s expertise and experience in management services. The consideration was paid for such services.