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    <title>2025 (8) TMI 530 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai held that reimbursements received by the assessee for expenses related to seconded employees and the UK branch of HDPI were not taxable as fees for technical services, as these payments lacked any element of profit or markup. The Tribunal relied on its prior decision for AY 2011-12, where similar reimbursements were held non-taxable. The Assessing Officer&#039;s addition was rejected, and the CIT(A)&#039;s order deleting the addition was upheld. The Revenue failed to provide new facts to justify a different conclusion. The assessee&#039;s appeal was allowed.</description>
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      <title>2025 (8) TMI 530 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=776343</link>
      <description>The ITAT Mumbai held that reimbursements received by the assessee for expenses related to seconded employees and the UK branch of HDPI were not taxable as fees for technical services, as these payments lacked any element of profit or markup. The Tribunal relied on its prior decision for AY 2011-12, where similar reimbursements were held non-taxable. The Assessing Officer&#039;s addition was rejected, and the CIT(A)&#039;s order deleting the addition was upheld. The Revenue failed to provide new facts to justify a different conclusion. The assessee&#039;s appeal was allowed.</description>
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