Allocation of enhanced FSI/TDR proceeds between cooperative society and individual flat-owners; tribunal deletes society LTCG addition, remits 80P ver...
Electronic Postal Bill of Export templates mandating specified data fields for postal export declarations; system-generated Let Export Order on public...
Reimbursements received from Indian group entities for actual salary costs of seconded employees could not be taxed as fees for technical services under section 9(1)(vii) and Article 12(4) of the India-Japan DTAA because the contracts and appointment letters established an employer-employee relationship between the secondees and the Indian entities, making the payments in substance salary and not consideration for rendering technical services; accordingly, the reimbursements were not recharacterizable as FTS and the addition was deleted, allowing the appeal. - ITAT
Reimbursements received from Indian group entities for actual salary costs of seconded employees could not be taxed as fees for technical services under section 9(1)(vii) and Article 12(4) of the India-Japan DTAA because the contracts and appointment letters established an employer-employee relationship between the secondees and the Indian entities, making the payments in substance salary and not consideration for rendering technical services; accordingly, the reimbursements were not recharacterizable as FTS and the addition was deleted, allowing the appeal. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
