Income from India: Taxed u/s 115A or India-Spain DTAA; Full receipts count, no exclusions for reimbursements.

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....Income accrued India - applying the tax rate as per section 115A OR tax rate as per the DTAA between India and Spain - in all cases of concessional taxation on gross receipt or revenue basis, splitting of total receipt into reimbursement or revenue, remains neutral to its chargeability. Both such cases, invariably warrant inclusion of the receipt in the revenue base for taxation so long as the receipt is relatable to costs incurred contributing to the earning of the revenue. An assessee cannot be permitted to opt for concessional rate of taxation on gross receipt basis and then claim that some part of the receipts should be left out by describing it as reimbursement. It is patently an absurd proposition. - AT....