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Issues: Whether reimbursement of actual expenses incurred by the assessee could be treated as its income for the year under consideration.
Analysis: The assessment year in question was held to be materially identical to the immediately preceding years, in which the Tribunal had already examined the same service arrangement and the character of the receipts. Following the earlier decision, the reimbursement of actual expenditure was held not to constitute income of the assessee. The matter of verification of the actual reimbursable amount was left to the Assessing Officer for giving effect to the conclusion.
Conclusion: Reimbursement of actual expenses is not taxable as income of the assessee; the addition was directed to be deleted after verification, in favour of the assessee.