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44. The ld. counsel for the assessee laid emphasis on the observations of the Special Bench wherein they have emphasized that mere reimbursement of expenses cannot have an element of turnover. He also emphasized that for a receipt to be called as turnover, there should be an element of income embedded in such receipt. When a receipt does not have an element of income embedded, then it cannot be called as turnover. According to him, the aforesaid decisions clearly lay down the proposition that inter-unit expenses incurred by one unit on behalf of the other unit cannot be considered as total turnover of the unit incurring the expenses in getting it reimbursed by the other unit. It was also pointed out by him that the unit providing services recognizes the expenses in the debit side of the ITA Nos. 1093/B0/09, 1266/B/10 & 1057 & 1103/B/12 profit & loss account and also recognizes the receipt on the credit side of the profit & loss account, thereby having NIL effect on the profits as per the profit & loss account. The unit receiving the services claims the expenses incurred by the other unit as expenses and thereby profits of the unit receiving the benefit of services provided by the other unit gets reduced to that extent. It was his submission that there is no attempt on the part of the assessee in either of the units to either decrease the total turnover or increase the profits of the business, thereby discharging the claim for deduction u/s. 10B of the Act.