Held that the authorities below had completely failed to take into consideration the relevant pieces of evidence filed as additional evidence. The Dispute Resolution Panel had fallen in error in considering the services to be in consultancy and professional services to the Indian associates. In spite of accepting that it was a reimbursement expense the Dispute Resolution Panel considered it to be substantially fees for technical services in nature. The assessee had not added any value to the laboratory report. The assessee had not played any role except for being a medium to procure a report from a laboratory having higher credibility. This could not at all be in the nature of fees for technical services, as erroneously held by the tax authorities..(AY.2013-14)