https://www.taxtmi.com/caselaws?id=120793 Pure reimbursement of verified pre-development expenses paid to non-resident shareholders, without any profit element, is not treated as consideration for technical services and does not attract withholding tax under section 195(2). The analysis notes that the payments were limited to actual costs, supported by audit certification, and paid under the shareholders' arrangement for project feasibility and development work. Because the underlying expenditure was incurred outside India and the later reimbursement was not itself a taxable fee for services, no tax was deductible at source on these facts. en-us Mon, 17 Dec 2007 00:00:00 +0530 Mon, 29 Jan 2024 16:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=120793 Pure reimbursement of verified pre-development expenses paid to non-resident shareholders, without any profit element, is not treated as consideration for technical services and does not attract withholding tax under section 195(2). The analysis notes that the payments were limited to actual costs, supported by audit certification, and paid under the shareholders' arrangement for project feasibility and development work. Because the underlying expenditure was incurred outside India and the later reimbursement was not itself a taxable fee for services, no tax was deductible at source on these facts. Case-Laws Income Tax Mon, 17 Dec 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=120793