...disallowance of Rs.74,57,621/- however deleted the addition / disallowance of Rs.32,93,383/- which was as per the direction of the Tribunal was towards reimbursement of expenditure wherein, no TDS provision...addition of Rs.32,93,383/- was directed to be deleted because it related to expenses where no TDS provision was applicable, he not only upheld the addition made by the AO but also further enhanced it...by making the disallowance of Rs.32,93,383/- without providing any opportunity or notice of hearing to the assessee. He held that even if it is a reimbursement to a parent company, TDS is deductible...