No markup chargeable in case of pure reimbursement of expenditure by AE

Capgemini India Pvt. Ltd. Vs DCIT (ITAT Mumbai) Facts- Assessee filed its return of income on 7 October 2010 declaring income of ₹113,19,82,875/-. As the assessee has entered into several international transactions, reference was made to the Learned Additional Commissioner of Income-Tax, Transfer Pricing, 1(3), Mumbai for determination of arm’s length price of those transactions. The draft assessment order was passed on 13th March, 2014 where several additions were made and total income was determined at ₹144,06,06,540/-. Assessee did not file any objection before the learned DRP against...