Reimbursements paid by the assessee to third-party vendors for...

Reimbursements paid by the assessee to third-party vendors for marketing events organized for its AE, and recovered on a cost-to-cost basis, were held not to constitute an international transaction involving services, as the assessee merely facilitated payments without value addition; consequently, no separate mark-up could be imputed and the TP adjustment was deleted. Year-end provisions for installation/authorised services and sales commission were held allowable if not ad hoc and reversed in the immediately succeeding year; the installation/authorised services provision was remanded for AO verification of a scientific basis and, if proved, to be allowed. Book profits under section 115JB and interest were directed to be recomputed/verified as per law. - ITAT