AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

57 of the Act are to be allowed, which in the present case would result in NIL income to Ahlstrom Corporation, Finland, since it is a case of pure reimbursement with no mark-up. (iv) Even otherwise, in terms of section 195 of the Act, since reimbursement of expenses is without any mark-up, the provisions of section 195 cannot