Committed & obligated payment are reimbursement of expenses & not fee for technical service

DCIT Vs Michlin Global Mobility (ITAT Delhi) ITAT Delhi held that the social security, insurance, relocation expenses which are in the nature of committed and obligated payments are in the nature of reimbursements and not fee for technical services. Facts- During the course of the scrutiny assessment proceedings the assessee was asked to explain why the amount received from the group entity in India was not taxable in India. The assessee explained with respect to the activities in India the assessee made available expatriates to Miscelin Group Entities in India i.e. AIMPL and MITC. This group ...