Fact that third party invoices are paid not necessarily means ‘reimbursement’

Apart from arguing that the payments were in the nature of reimbursement of expenses, the assessee has not explained anything about the pricing of the services, for which the so-called reimbursements were made by the Indian subsidiary to the assessee company. It is the case of the assessee that expenses were reimbursed by the Indian subsidiary at par with the invoices issued by third parties.

But there is nothing on record to show that the price negotiated between the assessee and the third parties and the amounts reflected in

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