https://www.taxtmi.com/caselaws?id=21049 HC upheld the Tribunal's finding that the arrangement between the assessee and M/s ETAG was not a device to evade income tax provisions and that amounts received were mere reimbursements of actual expenses. Applying SC precedent, HC held that reimbursement of expenses, to the extent they are wholly and necessarily incurred, cannot constitute taxable revenue receipts, and only any surplus, if proved, could be taxed. Since the Revenue had not challenged the incurring of expenses before the Tribunal and the original disallowance was solely under s.37 read with r.6D, no substantial question of law arose. The application by the Revenue was accordingly dismissed. en-us Mon, 20 Jul 1992 00:00:00 +0530 Thu, 11 Dec 2025 15:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21049 HC upheld the Tribunal's finding that the arrangement between the assessee and M/s ETAG was not a device to evade income tax provisions and that amounts received were mere reimbursements of actual expenses. Applying SC precedent, HC held that reimbursement of expenses, to the extent they are wholly and necessarily incurred, cannot constitute taxable revenue receipts, and only any surplus, if proved, could be taxed. Since the Revenue had not challenged the incurring of expenses before the Tribunal and the original disallowance was solely under s.37 read with r.6D, no substantial question of law arose. The application by the Revenue was accordingly dismissed. Case-Laws Income Tax Mon, 20 Jul 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21049