Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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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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