Reimbursements for seconded employees and UK branch expenses not taxable as Fees for Technical Services under ITAT ruling

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....The ITAT upheld the deletion of additions made to the assessee's income on account of reimbursements received for expenses related to seconded employees and the UK branch of HDPI. The Tribunal affirmed that such reimbursements, including payroll, rent, and miscellaneous expenses, lacked any element of profit or markup and thus did not constitute fees for technical services (FTS) taxable in the assessee's hands. Consistent with prior rulings in identical factual matrices, the Tribunal found no justification for treating these reimbursements as taxable income. The Revenue failed to present any new evidence or arguments to overturn the established position. Consequently, the CIT(A)'s order deleting the additions was upheld, and the assessee's appeal was allowed.....