Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Reimbursement of salary cost for seconded employees was not taxable as fees for technical services where the secondees worked under the control of the Indian entity and the payment contained no separate service element. Applying the earlier ruling in the group concern case, the ITAT found no material factual distinction for the year under consideration and treated the receipt as falling within the employer-employee salary exclusion. The addition made on that basis was deleted. The challenge to the validity of the assessment order was not pressed and was therefore not admitted.
Reimbursement of salary cost for seconded employees was not taxable as fees for technical services where the secondees worked under the control of the Indian entity and the payment contained no separate service element. Applying the earlier ruling in the group concern case, the ITAT found no material factual distinction for the year under consideration and treated the receipt as falling within the employer-employee salary exclusion. The addition made on that basis was deleted. The challenge to the validity of the assessment order was not pressed and was therefore not admitted.
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