Assessee, a multinational company, had made reimbursement to non-residents associated enterprises (AEs). Assessing Officer held that said payment would fall within purview of section 9(1)(vii) and were therefore taxable in India as fee for technical services (FTS).Accordingly, he made disallowance under section 40(a)(i) on account of non-deduction of tax under section 195 on reimbursement of expenses.  Commissioner (Appeals) and Tribunal deleted disallowance. On appeal the court held that   since Revenue was not able to establish that said remitted fee would fall within ambit of any technical, managerial or consultative service that had been rendered, no substantial question of law arose for consideration.