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Reimbursement of expenses by foreign head office to Indian liaison office cannot be treated as supply


Last updated: 02 February 2021

Court :
Hon'ble AAR, Haryana

Brief :
The Hon'ble AAR, Haryana, in the matter of M/S. Wilhelm Fricke SE [Advance Ruling No. HAR/HAAR/R/2019-20/24, decided onJune 25, 2020] held that, the Germany based head office and Indian Liaison Office ("LO") cannot be treated as separate persons as no consideration for any services is being charged by the LO. Hence, there cannot be any flow of services between them as one cannot provide service to self and therefore, the reimbursement of expenses made by the head office cannot be treated as a consideration towards any service.

Citation :
of M/S. Wilhelm Fricke SE [Advance Ruling No. HAR/HAAR/R/2019-20/24, decided on June 25, 2020]

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Bimal Jain
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