American Express (India) Pvt. Ltd. v. JCIT (2021) 92 ITR 576 (Delhi)(Trib.)

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Travelling expenses to employees-cannot be treated as fees for technical services. [S. 92CA]

Held that travelling expenses to employees cannot be treated as fees for technical services. (AY.2012-13, 2013-14)