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2018 (3) TMI 1991 - HC - Income TaxIncome taxable in India - Liability to tax on interest - Reimbursement of expenses - Data processing fees paid by the assessee to its overseas branch at Singapore is in the nature of interest - HELD THAT:- The question as proposed has became academic in view of the fact that the alternative 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 aforesaid findings of fact by the Tribunal is not the subject matter for challenge before us by the Revenue. It is also an agreed position between the Counsel that the issue of reimbursement of expenses is now in similar circumstances been held to be not chargeable to tax A.P. Moller Maersk A/S [2017 (2) TMI 993 - SUPREME COURT - No substantial question of law.
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