https://www.taxtmi.com/caselaws?id=65227 Reimbursement of actual salaries paid to employees deputed from group hotels was held not to fall within fees for professional or technical services under section 194J, because the deputed personnel were acting as employees and not rendering independent consultancy or professional services. The agreement separately distinguished technical consultancy fees from expense reimbursement, confirming that the salary payments were distinct from service consideration. As the amounts represented salary income already chargeable under the head "salaries", no further tax deduction obligation arose on the assessee for the reimbursed sums. The consequential demand under section 201 and interest under section 201(1A) were therefore unsustainable. en-us Thu, 11 Nov 2004 00:00:00 +0530 Sat, 22 Jun 2024 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65227 Reimbursement of actual salaries paid to employees deputed from group hotels was held not to fall within fees for professional or technical services under section 194J, because the deputed personnel were acting as employees and not rendering independent consultancy or professional services. The agreement separately distinguished technical consultancy fees from expense reimbursement, confirming that the salary payments were distinct from service consideration. As the amounts represented salary income already chargeable under the head "salaries", no further tax deduction obligation arose on the assessee for the reimbursed sums. The consequential demand under section 201 and interest under section 201(1A) were therefore unsustainable. Case-Laws Income Tax Thu, 11 Nov 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65227