Reimbursement of expense at cost not taxable as Fees for Technical Services

DCIT Vs Jefferies International Ltd. (ITAT Mumbai) ITAT Mumbai held that that reimbursement of expenses at cost is not taxable as fees for technical services since there is no element of income attached to the transaction. Accordingly, revenue’s appeal dismissed. Facts- The assessee is a non-resident corporate entity, incorporated in United Kingdom and is a tax resident of UK. The assessee has a subsidiary in India, being Jefferies India Private Ltd. (JIPL), which is registered with Securities and Exchange Board of India (SEBI), as a Category 1 Merchant Banker and a stock broker. The princip...