Payment by agent of assessee for purchases/ upgrades of software cannot be reimbursement

IN THE ITAT MUMBAI BENCH ‘L’ ACIT vs. First Advantage (P.) Ltd. IT Appeal Nos. 3029 and 3030 (Mum.) of 2010 [Assessment years 2008-09 and 2009-10] May 18, 2012 ORDER J. Sudhakar Reddy, Accountant Member – The present appeals preferred by the Revenue, are directed against impugned separate but identical order dated 28th January 2010, passed by the Commissioner (Appeals)-X, Mumbai, for assessment years 2008-09 and 2009-10 respectively. 2. The facts, as brought out by the Commissioner (Appeals) vide Paras-1.1 to 1.1.2, in his order, are extracted below:- “...