Pure reimbursement does not give rise to any income & cannot be treated as FTS

Synamedia Ltd. [formerly known as ‘NDS Limited’] Vs ACIT (ITAT Bangalore) It is the case of the Assessee that the receipts in question are pure reimbursement of expenses incurred by the Assessee for and on behalf of NDS Pay TV. It is the case of the revenue that (Para 2.1 of AO’s order) that reimbursement of expenses may be made by the service provider at actual or alternatively, the agreement may provide a fixed amount towards reimbursement and that the issue that generally arises in such cases is to see whether such reimbursements of expenses is purely reimbursement or for rendering se...