In the result, the appeal of the Revenue is allowed for statistical purpose

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1319, 1320, 1321, 1322 & 1323/Chny/2024 िनधा<रण वष< /Assessment Years:2014-15, 2015-16, 2016-17, 2017-18 & 2020-21 Janet Christine Depenning, The Income Tax Officer, 120, Velachery Main Road, Vs. International Taxation Ward-1(1), Guindy,Chennai – 600 032. Chennai. [Pan: Aebpd 2408L]

Section 9(1)(vii) were satisfied. ITA Nos.1319 to 1323/Chny/2024 :- 13 -: 21. As regards the Ld. AR’s contention that the assessee had acted only as a facilitator or pass through entity while making payments to the foreign attorney and on that ground the payment made were in the nature of pure reimbursement. In support of this averment