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    <title>2015 (3) TMI 792 - ITAT DELHI</title>
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    <description>Receipts claimed as reimbursement were not accepted as proved reimbursements because the assessee did not produce primary contemporaneous evidence of actual expenditure, the allocation basis, or a reliable one-to-one nexus between the costs incurred and the amounts recovered from the associated enterprise. Debit notes and general policy documents were held insufficient to discharge the burden of proof, and prior-year treatment did not control the year in issue because each assessment year must be decided on its own facts. The claim of pure reimbursement was therefore rejected, but the receipts were nevertheless held assessable under section 44BB in view of their connection with mineral oil operations and the services involved.</description>
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      <title>2015 (3) TMI 792 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=257858</link>
      <description>Receipts claimed as reimbursement were not accepted as proved reimbursements because the assessee did not produce primary contemporaneous evidence of actual expenditure, the allocation basis, or a reliable one-to-one nexus between the costs incurred and the amounts recovered from the associated enterprise. Debit notes and general policy documents were held insufficient to discharge the burden of proof, and prior-year treatment did not control the year in issue because each assessment year must be decided on its own facts. The claim of pure reimbursement was therefore rejected, but the receipts were nevertheless held assessable under section 44BB in view of their connection with mineral oil operations and the services involved.</description>
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