Tribunal Questions 13% Markup on Reimbursement Expenses; Seeks Clarity on Assessee's Role in Transactions.

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....Accrual of income - Reimbursement of expenses treated as income of the Assessee - Application of Markup on Reimbursement Expenses: The contentious issue was whether the Assessee should apply a markup on these reimbursement expenses. The Commissioner had directed a 13% markup, a decision that was challenged. The Tribunal remanded this issue back to the Commissioner for a detailed examination of whether the Assessee's role was merely as a conduit or if it played a significant role that could justify the markup.....