Court Rules Payment from TIL as Reimbursement, Not Fee for Technical Services; Assessee Not Ultimate Beneficiary.

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....Nature of receipt from TIL - payment of reimbursements - Assessee was not the ultimate beneficiary of the sum in question nor did it render any service to TIL. There is no basis on which the AO came to the conclusion that the sum in question was FTS in the hands of the Assessee. - AT....