Income from Support Services in India Not Considered FIS; Payments Deemed Reimbursement for Actual Expenses.

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....Income accrued in India - Amount received for providing ‘Support Service’ treated as Fees for Included Services (FIS) - Merely because the training program was of boarding nature, that cannot change the nature of program to fall in the purview of services, for which consideration should be FIS. Rather the consideration was in the form of reimbursement of expenses on actual basis of constituents like travelling, food, boarding and lodging of consultants employed by Indian Counterpart. The cost of training recovered from the Indian Associate was due to these expenditures on the trainees. - AT....