Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
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Salary reimbursement for seconded employees was held not to be fee for technical services where, during secondment, the employees were released from the foreign entity, worked solely for the Indian company, and remained under its exclusive control, direction and supervision. The Indian company bore the salary cost, could evaluate, discipline, suspend and terminate the secondees, and tax was deducted in India on the salary payments. A small administrative disbursement made in Japan and reimbursed without markup did not change the character of the payment. The Tribunal therefore deleted the FTS addition and distinguished Centrica India Offshore on the facts; the same conclusion applied to the connected appeals.
Salary reimbursement for seconded employees was held not to be fee for technical services where, during secondment, the employees were released from the foreign entity, worked solely for the Indian company, and remained under its exclusive control, direction and supervision. The Indian company bore the salary cost, could evaluate, discipline, suspend and terminate the secondees, and tax was deducted in India on the salary payments. A small administrative disbursement made in Japan and reimbursed without markup did not change the character of the payment. The Tribunal therefore deleted the FTS addition and distinguished Centrica India Offshore on the facts; the same conclusion applied to the connected appeals.
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