In the instant case, the employees of ‘I’ Ltd. were deputed to the assessee-AOP. The ‘I’ Ltd. has directly paid salaries and other related expenses to its employees and since the assessee has used the services of those employees, it has recovered the same from the assessee. Hence, in the hands of the assessee, what was paid to ‘I’ Ltd. was reimbursement of expenses. Allowing the appeal of the assessee the Tribunal held that ;there is considerable force in the arguments of the assessee. A combined reading of sections 40(ba) and 67A would make it very clear that the payments contemplated in section 40(ba) should constitute “Share income from AOP in the hands of the recipient member. In the instant case, the payments made by the assessee to ‘I’ Ltd. did not constitute ‘Share income’ in the hands of ‘I’ Ltd., but it merely offsets the expenditure incurred by it, i.e., the money had been received by ‘I’ Ltd. towards reimbursement of expenses incurred by it on its employees on behalf of the assessee.  ( AY.2008 -09)