Cost to Cost Reimbursement not held as FTS

The Income Tax Appellate Tribunal, Delhi Bench, held that genuine cost-to-cost reimbursements made by an Indian subsidiary to its overseas group entities towards IT infrastructure, seconded employee salaries and travel expenses, without any profit element, cannot be characterised as Fees for Technical Services (FTS). 

Consequently, no tax was deductible under Section 195 and the corresponding disallowance under Section 40(a)(i) was deleted.