Sanjay Karol, J.

All the appeals stand admitted on following substantial questions of law:

i. Whether the Hon’ble ITAT has erred in law in holding that the payments made by the assessee i.e. H.P. Bus Stand Management Development Authority, Bus Stand, Shimla to HRTC are not liable for deduction of tax at source as per provisions of Chapter XVII of the I.T. Act, 1961?

ii. Whether the Hon’ble ITAT has erred in upholding the order of ld. CIT(A) deleting the addition made by AO u/s 40(a)(ia) of the I.T. Act, 1961, especially in view of the judgment of the Hon’ble Punjab & Haryana High Court in the case of P.M.S. Diesel Vs. CIT-2, Jalandhar & others, dated 29.4.2015, (ITA No.716 of 2009)?

2. The sole issue which arises for consideration is as to whether arrangement arrived at inter se M/s. Himachal Pradesh Bus Stand Management Development Authority (hereinafter referred to as the Development Authority) and Himachal Pradesh Road Transport Corporation (hereinafter referred to as HRTC), can be said to be in the nature of latter providing professional or technical services to the former? Incidentally, what is argued is also that reimbursement of expenditure incurred by the latter would