20% Tax on Reimbursements Without Markup Under India-Italy DTAA Deemed Unjustifiable as Royalty.

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....Chargeability of tax @ 20% as royalty under the Indian Italy DTAA, the amounts recovered towards reimbursement of expenses - Such reimbursement of expenses without any mark up does not justify its taxability in the hands of assessee being royalty @ 20%. - AT....