Reimbursement of technical expenses-Cost Allocation: Non-Taxable

Bureau Veritas-Indian Division Vs ADIT (ITAT Mumbai)

Technical expenses allocated by head office to assessee-Indian division was in nature of reimbursement of technical expenses to head office and not on account of any specific technical services having been ‘made available’ and, therefore, such amount could not be brought to tax in hands of assessee under article 13 of Indo-French Tax Treaty. Also, said amount could not also be taxed in hands of assessee under article 7 as it was not an income ‘attributable to PE’.
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