Tribunal held that assessee failed to substantiate on basis of any clinching evidence that consideration received for services rendered by it to Indian Hotels were in nature of reimbursement of expenses incurred by assessee and there was no markup or profit made by rendering said services, its claim that same not being in nature of income, was not liable to be taxed in India, could not be accepted .( AY.2009 -10)
Renaissance Services BV. v. DIT (IT) (2018) 171 ITD 381 / 171 DTR 30/ 195 TTJ 1049 (Mum) (Trib.)
S. 9(1)(i): Income deemed to accrue or arise in India– Reimbursement of expenses – Failure to substantiate on basis of any clinching evidence – Assessable as business income- India -Nether land . [ Art.7,12 ]