Reimbursable expenditure received by the assessee cannot form part of the total income under DTAA between India and USA

Reimbursable expenditure and the fee payable for technical services under DTAA between India and USA- the reimbursable expenditure received by the assessee cannot form part of the total income since the development of infrastructure falls within the industrial policy of Government of India specific approval may not be required for claiming exemption u/s. 10(6A) of the Act. – what was reimbursed is the service tax paid by the assessee to the Government account. therefore, such an amount cannot form part of technical fee. In other words, it cannot be treated

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