Reimbursements received by a foreign company for travelling expenditure incurred for earning royalty/ FTS income taxable on gross basis under India-Singapore tax treaty

CSC Technology Singapore Pte. Ltd., Singapore Vs. ADIT (ITAT Delhi) Traveling  expenses have been incurred in connection with technical services agreement. Therefore, the expenditure has been incurred for earning royalty/FTS. In spite of the fact that the agreement provides inter-alia for adequate level of support and posting its personnel, the expenses for which will be reimbursed, the fact remains that the expenditure has been incurred for earning the royalty/FTS. The  expenditure is that of the assessee and not that of the Indian subsidiary company. Article 12 provides for taxation of ro...