https://www.taxtmi.com/caselaws?id=263335 Reimbursements towards Lotus Notes charges and other expenses were examined on the footing of whether they constituted fees for technical services or only recovery of actual costs incurred for associated enterprises. The existing record was insufficient because the service agreement was not produced, leaving the nature of the invoices, the reimbursement basis, and the exact character of the receipts unverified. The treaty position, including the included-services concept under Article 13(4)(c), was also not conclusively examined on a complete factual foundation. The additions were therefore not finally capable of being sustained or deleted, and the matter was restored to the Assessing Officer for fresh verification and decision. en-us Wed, 25 Feb 2015 00:00:00 +0530 Tue, 01 Sep 2015 07:32:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263335 Reimbursements towards Lotus Notes charges and other expenses were examined on the footing of whether they constituted fees for technical services or only recovery of actual costs incurred for associated enterprises. The existing record was insufficient because the service agreement was not produced, leaving the nature of the invoices, the reimbursement basis, and the exact character of the receipts unverified. The treaty position, including the included-services concept under Article 13(4)(c), was also not conclusively examined on a complete factual foundation. The additions were therefore not finally capable of being sustained or deleted, and the matter was restored to the Assessing Officer for fresh verification and decision. Case-Laws Income Tax Wed, 25 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263335