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    <title>2017 (1) TMI 1806 - ITAT DELHI</title>
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    <description>Reimbursements of out-of-pocket expenses, shown separately under the agreement and received without any markup or income element, were treated as not constituting fees for technical services under section 9(1)(vii) of the Income-tax Act, 1961 and Article 13 of the India-UK DTAA; this point was accepted in favour of the assessee. Consideration for introductory educational programmes and workshops was not accepted as exempt merely because of its educational label, since the assessee was not an educational institution and the receipt remained linked to technical services; this point was decided against the assessee. The result was partial relief, with reimbursement receipts excluded from FTS taxation and workshop-related receipts upheld as taxable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=306478</link>
      <description>Reimbursements of out-of-pocket expenses, shown separately under the agreement and received without any markup or income element, were treated as not constituting fees for technical services under section 9(1)(vii) of the Income-tax Act, 1961 and Article 13 of the India-UK DTAA; this point was accepted in favour of the assessee. Consideration for introductory educational programmes and workshops was not accepted as exempt merely because of its educational label, since the assessee was not an educational institution and the receipt remained linked to technical services; this point was decided against the assessee. The result was partial relief, with reimbursement receipts excluded from FTS taxation and workshop-related receipts upheld as taxable.</description>
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