Reimbursement can be described as repayment of what has already been spent or incurred. Therefore, it should not be considered a reward or compensation for a service rendered.
Section 79 has no application in the absence of change in the beneficial voting power. Even after transfer of shares in the assessee company by its ultimate holding company to its another subsidiary, beneficial ownership of the assessee company continued to vest with the same holding company and therefore provisions of section 79 would not apply.
