https://www.taxtmi.com/caselaws?id=776760 Cost-to-cost reimbursement of legal and professional expenses, supported by third-party invoices and accepted on facts as having no markup, was held not to constitute taxable income in the non-resident recipient's hands under Article 13 of the India-Denmark DTAA. Because the assessment order did not dislodge the reimbursement character and no profit element was shown to be embedded in the receipt, the amount could not be recharacterised as royalty or management fee for treaty taxation. The transfer pricing treatment in the payer's hands did not change the tax character of the same receipt in the recipient's hands, and the addition was therefore unsustainable. en-us Tue, 07 Jan 2025 00:00:00 +0530 Tue, 19 Aug 2025 08:38:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776760 Cost-to-cost reimbursement of legal and professional expenses, supported by third-party invoices and accepted on facts as having no markup, was held not to constitute taxable income in the non-resident recipient's hands under Article 13 of the India-Denmark DTAA. Because the assessment order did not dislodge the reimbursement character and no profit element was shown to be embedded in the receipt, the amount could not be recharacterised as royalty or management fee for treaty taxation. The transfer pricing treatment in the payer's hands did not change the tax character of the same receipt in the recipient's hands, and the addition was therefore unsustainable. Case-Laws Income Tax Tue, 07 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776760