Expense Reimbursement Not Classified as Fees for Technical Services Under Article 12(4) of India-Singapore DTAA.

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....Taxability of reimbursement of expenses as FTS - the recipients are receiving such services on a continuous basis from year to year, which shows that the recipients are not capable of independently performing such services without the aid and assistance of the assessee. - the reimbursement of cost received by the assessee, cannot be treated as FTS under Article 12(4) of the India-Singapore DTAA, at least, based on the facts involved in the impugned assessment years. - AT....