Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
Industrial shrimp-feed machinery classification follows its commercial function, placing integrated production plants under the specific industrial fo...
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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