Reimbursement of exp. to foreign AE was taxable if no nexus was found between services rendered and

IT/ILT : Where assessee-company, a tax resident of UK, had received certain sum from a foreign company which was engaged in exploration and production of oil in oil fields of India and claimed same to be reimbursement of actual cost, but could not establish one to one nexus between services rendered to said company and alleged reimbursement, it would be fair to tax assessee's receipts under section 44BB