TMI Blog2018 (3) TMI 1987X X X X Extracts X X X X X X X X Extracts X X X X ..... ive submission made by the respondent before the authorities was that the payment made to its overseas branch at Singapore in respect of the data processing fees was really in the nature of reimbursement. The impugned order of the Tribunal has on facts found that the payment made by the respondent assessee to it overseas branch at Singapore was in the nature of reimbursement of expenses. The af ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ection 260-A of the Income Tax Act, 1961 (the Act) challenges the order dated 21st November, 2014 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order is in respect of Assessment Year 2007-08. 2. The Revenue has urged only the following re-framed question of law for our consideration : - (i) Whether on the facts and circumstances of the case, the Tribunal was justi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Counsel that the issue of reimbursement of expenses is now in similar circumstances been held that to be chargeable to tax by the Apex Court in Director of Income Tax Vs. A.P. Moller Maersk A/S, 392 ITR 186. 4. In the above view, the question of law as proposed being academic, does not give rise to any substantial question of law. Therefore, not entertained. 5. Appeal is dismissed. N ..... X X X X Extracts X X X X X X X X Extracts X X X X
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