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2015 (3) TMI 1024 - ITAT BANGALORE

2015 (3) TMI 1024 - ITAT BANGALORE - TMI - Transfer pricing adjustment - Computation of Arms Length Price - selection of comparable - Held that:-Flextronics Software Systems Ltd. 595.12 crores and Infosys Technologies Ltd. 9028.00 crores whose turnover is above ₹ 200 Crores should be excluded from the list of comparable companies. The AO is directed to compute the Arithmetic mean by excluding the aforesaid companies from the list of comparable.

Respectfully following the decisio .....

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cordingly, we direct exclusion of Megasoft Ltd., Aztech Software Ltd. and Geometric Software Ltd. from the comparables. See Agile Software Enterprise Private Limited, C/o. Oracle India Private Ltd. Versus The Income Tax Officer [2015 (1) TMI 600 - ITAT BANGALORE]

Inclusion of the reimbursement of expenses by the AE to the Assessee as part of the operating cost while working the adjustment on account of ALP - Held that:- It is clear from the decision rendered by the co-ordinate bench i .....

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e into the question as to whether the receipt in question is reimbursement. We therefore remand the issue to the limited extent of verification regarding the nature of the receipt only and hold that if the receipts are purely reimbursement of expenses they should neither be considered as operating income nor operating expenses for the purpose of calculating margins of the Assessee. - Decided partly in fvaour of assessee for statistical purposes. - I.T(TP).A No.1311/Bang/2010 - Dated:- 20-3-2015 .....

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usiness providing software development Services to group companies. During the previous year, the Assessee entered into the following international transactions viz., The business of the Assessee is organized into three divisions viz., (1) Software Development Services from which it received a sum of ₹ 7,51,78,503 from its Associated Enterprise (AE) (2) Reimbursement of expenses received from its AE of ₹ 27,02,741/- (3) Reimbursement of expenses paid of ₹ 14,23,145/-. The Asses .....

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with its AE in respect of (1) Software development Services and (2) Reimbursement of expenses received from AE. 3. Financial Results of the Assessee for the F Y 2005-06 Description Amount Operating Revenue Rs.7,51,78,503/- Operating Cost . . . . Rs.6,75,15,662/- Operating Profit (PBIT) Rs.76,62,841/- Operating Profit to Cost Rati 11.35% International Transactions (as mentioned in the 92 CE report) : Software development Services - ₹ 7,51,78,503/- Reimbursement of expenses received - ₹ .....

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tems International Ltd. (Seg.) 22.20 79.42 8 Sasken Communications Ltd. (Seg.) 13.90 240.03 9 Tata Elxsi Ltd (Seg.) 27.65 188.81 10 Lucid Software Ltd 8.92 1.02 11 Mediasoft Solutions Ltd 6.29 1.76 12 R S Software (India) Ltd 15.69 91.57 13 S I P Technologies & Exports Ltd 3.06 6.53 14 Bodhtree Consulting Ltd. 15.99 5.32 15 Accel Transmatic Ltd. (Seg.) 44.07 8.02 16 Synfosys Business solutions Ltd. 10.61 4.49 17 Flextronics Software Systems Ltd. 27.24 595.12 Lanco Global Solutions Ltd 5.27 3 .....

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t Level indicators is taken as the arms length margin. (Please see Annexure B For details of computation of PLI of the comparables). Based on this, the arms length price of the software development services rendered by you is computed as under: Arithmetic mean PLI 20.68% Less: Working capital Adjustment(Annexure-C) -4.75% Adj.Arithmetic mean PLI 25.43% Arm s Length Price: Operating Cost 6,75,15,662+ ₹ 27,02,741* Rs.7,02,18,403 Arms Length Margin 25.43% of the operating cost Arms Length Pri .....

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ed as transfer pricing adjustment u/s 92CA. 6. Against the said adjustment proposed by the TPO which was incorporated in the draft assessment order by the AO, the assessee filed objections before the DRP. The DRP rejected those objections and confirmed the transfer pricing adjustment suggested by the TPO. The adjustment confirmed by the DRP was added to the total income of the assessee by the AO in the fair order of assessment. Against the said order of the Assessing Officer, the assessee has pr .....

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se companies were not functionally comparable; (c) for the reason that the related party transaction (RPT) carried out by the comparable companies during the previous year was beyond 15% of its revenue and hence ought not to be included as a comparable. The Chart also gives the cases decided by various Benches of the ITAT where the comparable companies have been held to be not comparable with that of an Assessee providing IT Software development Services. The learned DR relied on the order of th .....

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the above two issues, viz., (1) excluding 6 companies from the final set of 20 comparable companies finally chosen by the TPO for the purpose of comparison and (2) excluding the sum of ₹ 27,02,741/- being reimbursement of expenses received from the AE as part of the operating cost, other issues raised in the grounds of appeal and the revised grounds of appeal were not pressed. 8. The ld. counsel for the assessee brought to our notice that out of the 20 comparable companies chosen by the T .....

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ation of turnover filter and it was submitted that the aforesaid comparable companies have to be excluded from the final list of comparable selected by the TPO. 9. We have considered the submission of the learned counsel for the Assessee and the learned DR. In the case of Triology E-Business Software India (P) Ltd. (supra), this Tribunal on application of the turnover filter while selecting comparable companies for comparability analysis held as follows: (1) Turnover Filter 11. The ld. counsel f .....

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cost charged or paid or profit arising from such transaction in the open market. Further it is also necessary to see that wherever there are some differences such differences should be capable of reasonable accurate adjustment in monetary terms to eliminate the effect of such differences. It was his submission that size was an important facet of the comparability exercise. It was submitted that significant differences in size of the companies would impact comparability. In this regard our attent .....

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Bench on this aspect would hold the field. Reference was also made to the OECD TP Guidelines, 2010 wherein it has been observed as follows:- Size criteria in terms of Sales, Assets or Number of Employees: The size of the transaction in absolute value or in proportion to the activities of the parties might affect the relative competitive positions of the buyer and seller and therefore comparability. 12. The ICAI TP Guidelines note on this aspect lay down in para 15.4 that a transaction entered i .....

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ences could either be with reference to the transaction or with reference to the enterprise. For instance, a transaction entered into by a ₹ 1,000 crore company cannot be compared with the transaction entered into by a ₹ 10 crore company. The two most obvious reasons are the size of the two companies and the relative economies of scale under which they operate. 13.It was further submitted that the TPO s range (Rs. 1 crore to infinity) has resulted in selection of companies like Infos .....

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was held to be proper. The following relevant observations were brought to our notice:- 9. Having heard both the parties and having considered the rival contentions and also the judicial precedents on the issue, we find that the TPO himself has rejected the companies which .ire (sic) making losses as comparables. This shows that there is a limit for the lower end for identifying the comparables. In such a situation, we are unable to understand as to why there should not be an upper limit also. .....

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of the Tribunal, when companies which arc loss making are excluded from comparables, then the super profit making companies should also be excluded. For the purpose of classification of companies on the basis of net sales or turnover, we find that a reasonable classification has to be made. Dun & Bradstreet & Bradstreet and NASSCOM have given different ranges. Taking the Indian scenario into consideration, we feel that the classification made by Dun & Bradstreet is more suitable and .....

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able Bangalore ITAT in the following cases: 1.M/s Kodiak Networks (India) Private Limited Vs. ACIT (ITA No.1413/Bang/2010) 2.M/s Genesis Microchip (I) Private Limited Vs. DCIT (ITA No.1254/Bang/20l0). 3.Electronic for Imaging India Private Limited (ITA No. 1171/Bang/2010). 16.It was finally submitted that companies having turnover more than ₹ 200 crores ought to be rejected as not comparable with the Assessee. 17. The ld. DR, on the other hand pointed out that even the assessee in its own .....

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rovides that international transaction means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises, and shall include a mutual agreement or arrangement between two or more associated enterprises for the allocation or .....

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n international transaction and it provides:- (1) that the arm s length price in relation to an international transaction shall be determined by any of the following methods, being the most appropriate method, having regard to the nature of transaction or class of transaction or class of associated persons or functions performed by such persons or such other relevant factors as the Board may prescribe, namely :- (a)comparable uncontrolled price method; (b)resale price method; (c)cost plus method .....

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length price so determined and price at which the international transaction has actually been undertaken does not exceed five per cent of the latter, the price at which the international transaction has actually been undertaken shall be deemed to be the arm s length price. (3) Where during the course of any proceeding for the assessment of income, the Assessing Officer is, on the basis of material or information or document in his possession, of the opinion that- (a)the price charged or paid in .....

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fied time, any information or document which he was required to furnish by a notice issued under sub-section (3) of section 92D, the Assessing Officer may proceed to determine the arm s length price in relation to the said international transaction in accordance with subsections (1) and (2), on the basis of such material or information or document available with him: Rule 10B of the IT Rules, 1962 prescribes rules for Determination of arm s length price under section 92C:- 10B. (1) For the purpo .....

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les effected or assets employed or to be employed by the enterprise or having regard to any other relevant base; (ii) the net profit margin realised by the enterprise or by an unrelated enterprise from a comparable uncontrolled transaction or a number of such transactions is computed having regard to the same base; (iii) the net profit margin referred to in sub-clause (ii) arising in comparable uncontrolled transactions is adjusted to take into account the differences, if any, between the intern .....

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to the international transaction. (2) For the purposes of sub-rule (1), the comparability of an international transaction with an uncontrolled transaction shall be judged with reference to the following, namely:- (a) the specific characteristics of the property transferred or services provided in either transaction; (b) the functions performed, taking into account assets employed or to be employed and the risks assumed, by the respective parties to the transactions; (c) the contractual terms (w .....

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nt and level of competition and whether the markets are wholesale or retail. (3) An uncontrolled transaction shall be comparable to an international transaction if- (i)none of the differences, if any, between the transactions being compared, or between the enterprises entering into such transactions are likely to materially affect the price or cost charged or paid in, or the profit arising from, such transactions in the open market; or (ii)reasonably accurate adjustments can be made to eliminate .....

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ation to the transactions being compared. A reading of the provisions of Rule 10B(2) of the Rules shows that uncontrolled transaction has to be compared with international transaction having regard to the factors set out therein. Before us there is no dispute that the TNMM is the most appropriate method for determining the ALP of the international transaction. The disputes are with regard to the comparability of the comparable relied upon by the TPO. In this regard we find that the provisions of .....

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Thus, companies having turnover of more than 200 crores have to be eliminated from the list of comparables as laid down in several decisions referred to by the ld. counsel for the assessee. Applying those tests, the following companies will have to be excluded from the list of 26 comparables drawn by the TPO viz., Turnover Rs. (1)Flextronics Software Systems Ltd. 848.66 crores (2) iGate Global Solutions Ltd. 747.27 crores (3) Mindtree Ltd. 590.39 crores (4) Persistent Systems Ltd. 293.74 crores .....

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the list of comparable companies. The AO is directed to compute the Arithmetic mean by excluding the aforesaid companies from the list of comparable. 11. Improper selection of comparables: It was submitted by the learned counsel for the Assessee that the following 2 companies are not functionally comparable with that of the Assessee. a) KALS Information Systems Limited b) TATA Elxsi c) Accel Transmission Limited. In this regard our attention was drawn to the decision of the Hon ble ITAT Bangalor .....

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thorised Representative submitted that the following four companies be excluded from the list of comparables selected by the TPO as they are functionally different and not comparable to the assessee. i) KALS Information Systems Ltd. ii) Tata Elxsi Ltd. (Seg). iii) Accel Transmatics Ltd. (Seg.) and iv) R Systems International Ltd. (Seg.) In this connection, the learned Authorised Representative drew the attention of the bench to the decision of the co-ordinate bench of this Tribunal in the case o .....

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e assessee. On a perusal of the decision of the co-ordinate bench of the Tribunal in the case of Agile Software Enterprises Pvt. Ltd. (supra) for Assessment Year 2006-07, relied upon by the assessee, we find that the following three companies were excluded from the TPO s list of comparables as they were held to be functionally different from the assessee, who was into pure software development services :- i) KALS Information Systems Ltd. ii) Tata Elxsi Ltd. (Seg). iii) Accel Transmatics Ltd. (Se .....

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iness Software (I) Pvt. Ltd. (supra). As per the ld. AR, same view was taken in EMC Data (supra) also. 8.7.1 Per contra, the ld. DR submitted that KALS Information Systems Ltd. could not be considered as a software product company. 8.7.2 We have perused the orders and heard the rival contentions. We find that KALS Information Systems Ltd. was considered as a software product company in both Trilogy ebusiness( supra) as well as EMCData (supra). In these decisions, a host of companies, inter alia, .....

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this company is engaged in providing training. It was also submitted that as per the annual repot, the salary cost debited under the software development expenditure was Q 45,93,351. The same was less than 25% of the software services revenue and therefore the salary cost filter test fails in this case. Reference was made to the Pune Bench Tribunal s decision of the ITAT in the case of Bindview India Private Limited Vs. DCI, ITA No. ITA No 1386/PN/1O wherein KALS as comparable was rejected for A .....

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not comparable to software development services provided by the assessee. The appellant has submitted an extract on pages 185-186 of the Paper Book from the website of the company to establish that it is engaged in providing of I T enabled services and that the said company is into development of software products, etc. All these aspects have not been factually rebutted and, in our view, the said concern is liable to be excluded from the final set of comparables, and thus on this aspect, assesse .....

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port of this company as highlighted by the Assessee in its letter dated 21.6.2010 to the TPO. We also find that in the decision referred to by the learned counsel for the Assessee, the Mumbai Bench of ITAT has held that this company was developing software products and not purely or mainly software development service provider. We therefore accept the plea of the Assessee that this company is not comparable. (e) Accel Transmatic Ltd. 48. With regard to this company, the complaint of the assessee .....

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005-06 from which the DRP noted that the business activities of the company were as under. (i) Transmatic system - design, development and manufacture of multi function kiosks Queue management system, ticket vending system (ii) Ushus Technologies - offshore development centre for embedded software, net work system, imaging technologies, outsourced product development (iii) Accel IT Academy (the net stop for engineers)- training services in hardware and networking,enterprise system management, em .....

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tionally different was accepted. DRP therefore directed the Assessing Officer to exclude ACCEL Transmatic Ltd. from the final list of comparables for the purpose of determining TNMM margin. Besides the above, it was pointed out that this company has related party transactions which is more than the permitted level and therefore should not be taken for comparability purposes. The submission of the ld. counsel for the assessee was that if the above company should not be considered as comparable. T .....

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re development services business. Accepting the argument of the ld. counsel for the assessee, we hold that the aforesaid company should be excluded as comparables. 13. The facts and circumstances under which the aforesaid companies were considered as comparable is identical in the case of the Assessee as well as in the case of Triology E-Business Software India Pvt.Ltd. (supra). Respectfully following the decision of the Tribunal referred to above in the case of Triology E-Business Software Indi .....

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egard given by the Tribunal. The assessee having relied on the decision of the Tribunal wherein it has been held that KALS is a software product company, unless the decision of a higher authority which is different from the one given by the coordinate Bench is shown by the revenue, it will not be possible to deviate from the view earlier taken by a coordinate Bench. Accordingly, we direct that KALS Information Systems Ltd. be excluded from the comparables. 8.8 Accel Transmatics Ltd.: Ld. AR rais .....

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at this company was engaged in research & development which resulted in creation of Intellectual Property Rights and therefore was a software product company. Reliance was placed on the decision of coordinate Bench of the Tribunal in the case of EMC Data (supra). 8.9.1 Per contra, the ld. DR submitted that Tata Elxsi Ltd. was not a software product company, but was engaged only in development of software. 8.9.2 We have heard the rival contentions. Whether Tata Elxsi Ltd. could be considered .....

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of Logica Pvt.Ltd. IT (TP) 1129/Bang/2011 AY 07-08) wherein on the aforesaid company, the Tribunal held as follows:- 14. As far as comparable at Sl.No.6 & 24 are concerned, the comparability of the aforesaid two companies with that of the software service provider was considered by the Mumbai Bench of the Tribunal in the case of Telcordia Technologies India Private Ltd. (supra) wherein on the aforesaid two companies, the Tribunal held as follows:- 7.7. Tata Elxsi Limited.: From the facts and .....

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nsider it as a comparable party for comparing the profit ratio from product and services. Thus, on these facts, we are unable to treat this company fit for comparability analysis for determining the arms length price for the assessee, hence, should be excluded from the list of comparable parties. 15. In view of the above, the ld. counsel for the assessee fairly admitted that comparable company at Sl.No.6 viz., Flextronics Software Systems Pvt. Ltd. should be taken as a comparable, while comparab .....

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f the Tribunal in the case of Yodlee Infotech Pvt. Ltd. (ITA No.1397/Bang/2010 dated 15.2.2013) as well. We therefore direct that Tata Elxsi Ltd. be excluded from the comparables. 8.2.3 Following the aforesaid decision of the co-ordinate bench of this Tribunal in the case of Agile Software Enterprises Pvt. Ltd. for Assessment Year 2006-07 (supra), we hold that the above mentioned three companies i.e. i) KALS Information Systems Ltd. ii) Tata Elxsi Ltd. (Seg). and iii) Accel Transmatics Ltd. (Seg .....

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gineering (supra), we direct that KALS InfoSystems Ltd. And Accel Transmatic Ltd. And TATA Elxsi be excluded from the list of 20 comparable arrived at by the TPO. 14. The learned counsel for the Assessee submitted that one of the comparable out of the 20 comparable companies chosen by the TPO viz., Megasoft Ltd., has related parties transaction exceeding 15% and therefore should not be regarded as comparable and in this regard drew our attention to the following observations of the ITAT Bangalor .....

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In support of their exclusion, the learned Authorised Representative has placed reliance on the decision of the co-ordinate bench of this Tribunal in the case of Agile Software Enterprises Pvt. Ltd. in IT(TP)A No.1172/Bang/2010 dt.26.9.2014; which is also for Assessment Year 2006- 07; the period under consideration. The learned Authorised Representative prayed that in view of the above, these three comparables be excluded from the list of comparable companies to the assessee. 7.2 We have heard .....

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other decisions of this Tribunal, has held that where the RPT exceeds 15%, such companies should not be taken as comparables. The operative portion of this order of the co-ordinate bench (supra) in paras 8.11 and 8.12 at pages 16 & 17 thereof is extracted hereunder :- 8.11 Megasoft Ltd. 8.12 Aztech Software Ltd. 8.13 Geometric Software Ltd. Ld. AR submitted that in each of the above companies the RPT filter exceeded 15%. According to him, RPT filter has been upheld by this Tribunal in a hos .....

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ge-4 of this order viz., Aztec Software Limited and Geometric Software Ltd. (Seg.) and Megasoft Ltd., is concerned, it is not in dispute before us that the related party transaction in the case of companies exceeds 15% and in view of the decision of the Tribunal in the case of 24 X 7 Customer.Com Pvt. Ltd. in ITA No.227/Bang/2010, followed by this Tribunal in the case of Logica Private Ltd. (supra) wherein it was held that where the RPT exceeds 15%, such companies should not be taken as comparab .....

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applying the RPT filter. Accordingly, we direct exclusion of Megasoft Ltd., Aztech Software Ltd. and Geometric Software Ltd. from the comparables. 7.3 Following the aforesaid decision of the co-ordinate bench of this Tribunal in the case of Agile Software Enterprises Pvt. Ltd. (supra), we hold that the aforesaid three companies listed at para 7.1 of this order be excluded from the list of comparables. 15. Following the aforesaid decision of the Tribunal, we hold that Megasoft Ltd., be excluded f .....

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simply added the same to the operating cost for the purpose of working out the ALP adjustment. Though it was highlighted in the objections before the DRP that the above expenses are in the nature of travelling expenses, hotel expenses, per diems, and visa and travel insurance charges etc., and are therefore not related to the consideration received by the Assessee for services rendered and are purely in the nature of out of pocket expenses, the DRP did not choose to consider the submissions and .....

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learned counsel for the Assessee submitted that the reimbursement of expenses can neither be treated as operating revenue or operating expense and should be wholly excluded from the profit and loss account. Our attention was also drawn to the agreement between the Assessee and its holding company wherein it was provided that the Assessee will reimburse expenses in relation to travel of Assessee s staff for onsite projects. It was thus submitted that reimbursement of expenses receivable should be .....

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