Sum received by 'HSBC Bank' towards protection fee for guaranteed portfolio performance not taxable as FTS in India

INTERNATIONAL TAXATION: Where assessee, a UK based company, received certain amount from its Indian group entities as reimbursement of expenses, in view of fact that said amount was in respect of specific and actual expenses incurred by assessee and it did not involve any markup, same could not be brought to tax in India as fee for technical service

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