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2015 (11) TMI 852 - AT - Income TaxComputation of income under section 44D - Reimbursement of expenses not treated as part of 'fees for technical services' by CIT(A)- Held that:- Commissioner of Income-tax (Appeals) while deciding the issue in favour of the assessee has relied on the decision of the hon'ble Cuttack Bench in the assessee's own case for the assessment year 2002-03 wherein considering this clause of the agreement with NHAI and the definition of 'fees for technical services', under the Income-tax Act, as well as, the definition of 'fees for technical services', under the Double Taxation Avoidance Agreement, the receipts in the nature of reimbursement of expenses, cannot be treated as, fees for technical services - Decided in favour of assessee.
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