https://www.taxtmi.com/caselaws?id=65231 Reimbursement of salary paid to deputed expatriate technicians was treated as salary-related expenditure rather than fee for technical services, because the technicians worked under the assessee's supervision and control, were placed at its disposal during deputation, and the payments were made on a cost-to-cost basis without profit element. The arrangement separately covered technology transfer, royalty and personnel deputation, supporting the view that the salary reimbursements fell outside section 195 and were instead covered by salary deduction under section 192. On that basis, the assessee had a reasonable basis for the tax treatment adopted and was not regarded as an assessee in default under sections 201(1) and 201(1A). en-us Tue, 26 Feb 2002 00:00:00 +0530 Mon, 14 Feb 2011 13:23:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65231 Reimbursement of salary paid to deputed expatriate technicians was treated as salary-related expenditure rather than fee for technical services, because the technicians worked under the assessee's supervision and control, were placed at its disposal during deputation, and the payments were made on a cost-to-cost basis without profit element. The arrangement separately covered technology transfer, royalty and personnel deputation, supporting the view that the salary reimbursements fell outside section 195 and were instead covered by salary deduction under section 192. On that basis, the assessee had a reasonable basis for the tax treatment adopted and was not regarded as an assessee in default under sections 201(1) and 201(1A). Case-Laws Income Tax Tue, 26 Feb 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65231