https://www.taxtmi.com/caselaws?id=793755 Pure reimbursements of IT infrastructure and software support, seconded employee salaries, and travel s paid to group entities were treated as cost-to-cost outgoings without any mark-up or profit element, so they were not characterised as fees for technical services and no disallowance for non-deduction of tax at source survived. The transfer pricing adjustment on delayed invoice realisation was also rejected because the six-month USD LIBOR application date adopted by the revenue was not prescribed by the governing arrangement, while the assessee's method was based on a publicly available rate used in good faith. The reimbursements and transfer pricing adjustment were deleted. en-us Fri, 19 Jun 2026 00:00:00 +0530 Tue, 23 Jun 2026 08:08:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793755 Pure reimbursements of IT infrastructure and software support, seconded employee salaries, and travel s paid to group entities were treated as cost-to-cost outgoings without any mark-up or profit element, so they were not characterised as fees for technical services and no disallowance for non-deduction of tax at source survived. The transfer pricing adjustment on delayed invoice realisation was also rejected because the six-month USD LIBOR application date adopted by the revenue was not prescribed by the governing arrangement, while the assessee's method was based on a publicly available rate used in good faith. The reimbursements and transfer pricing adjustment were deleted. Case-Laws Income Tax Fri, 19 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793755