No TDS on reimbursement of guarding and supervisory charges by assessee , rice mill, to bank for payment to NBHC (National Bulk Handling Corporation) against pledge of stock but tds required to be deducted by bank because there is contract between bank and NBHC. Hence 40(a) (ia) not attracted- Luxmi Rice Mills 29-10-2015 (2015) 45 CCH 0153 DelTrib. The Tribunal relied upon the decision of Gujrat High Court in Gujrat Narmada Valley Fertilizer Co. SLP against the decision of Gujrat High Court dismissed by Supreme Court on 17-01-2014 (in SLC CC No. 175 of 2014). Delhi High Court in the case of CIT Vs. DLF Commercial Project Corporation in ITA 627/2012 and 507/2013 vide order dated 15-7-2015 has also held that no TDS is liable to be deducted on reimbursement of expenses