ITAT explains basic conditions for Satisfaction of reimbursement Claim

Rieter Machine Works Limited Vs ACIT (ITAT Pune) Facts- The assessee rendered IT services of INR 20.04 Crores to group company and tax of 10% was paid pursuant to Master Services Agreement with RIPL. The assessee claimed an amount of INR 3,88,94,824 as reimbursement of IT licence cost incurred towards centrally purchasing software licenses on which no tax was paid. Conclusion-  To categorize a particular amount as reimbursement, it is sine-qua-non that the expenditure should be incurred for and on behalf of the other. It envisages two cumulative conditions, viz., first that undiluted benefit ...