Reimbursable expenditure cannot form part of fee payable for technical services under Indo-US DTAA

ORDER Per N.R.S. Ganesan, JM: All these appeals of the Revenue are directed against the independent orders of the CIT(A)-III, Hyderabad and pertains to the assessment years 1998-99, 1999-2000, 2000-01, 2001-02, 2002-03. Since common issues arise for consideration in all these appeals, we have heard the same together and disposing off the same by this common order. 2. The learned departmental representative submitted that during the course of assessment proceedings, the assessing officer disallowed Rs. 8,55,58,000/- towards expenditure claimed as reimbursable. According to learned departmental ...