https://www.taxtmi.com/caselaws?id=65402 Reimbursement of crew salary and related expenses paid to a foreign group company retained the character of salary where the crew were appointed by the Indian enterprise, worked under its control, and were placed at its disposal. On that basis, the payment was not fees for technical services and tax deduction was required under section 192, not section 195. The Tribunal also accepted that the non-deduction point did not sustain disallowance under section 40(a)(i) on these facts, so the crew-salary disallowance was deleted. The broader management-rights issue was remanded for fresh consideration. en-us Fri, 30 Jan 2009 00:00:00 +0530 Tue, 31 Jul 2012 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65402 Reimbursement of crew salary and related expenses paid to a foreign group company retained the character of salary where the crew were appointed by the Indian enterprise, worked under its control, and were placed at its disposal. On that basis, the payment was not fees for technical services and tax deduction was required under section 192, not section 195. The Tribunal also accepted that the non-deduction point did not sustain disallowance under section 40(a)(i) on these facts, so the crew-salary disallowance was deleted. The broader management-rights issue was remanded for fresh consideration. Case-Laws Income Tax Fri, 30 Jan 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65402