Charges towards reimbursement of expenses cannot be included in income
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The question as to whether a reimbursement for expenses would form part of the taxable income is not res integra insofar as this Court is concerned.
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In CIT v. Siemens Aktiongesellschaft [2009] 177 Taxman 81 (Bom.), a Division Bench of this Court held that sharing of expenses of the research utilised by the subsidiaries as well as the head office organization would not be income which would be assessable to tax.
HIGH COURT OF BOMBAY
DIT (Int’l Taxation)
v.
Krupp Udhe GmbH
ITA No. 2626 of 2009
March 9, 2010