https://www.taxtmi.com/caselaws?id=66017 The Tribunal allowed the appeals, setting aside the Commissioner's orders. It held that payments to foreign technicians were not taxable as salaries but as technical know-how fees or royalties, exempt under Section 9(1)(vii). The Tribunal determined no employer-employee relationship existed between BHEL and the technicians. It found the technicians eligible for exemption under the Double Taxation Avoidance Agreements with Germany and Italy, as well as under Section 10(6)(vi) of the Income-tax Act due to their short stay in India. en-us Thu, 30 Apr 1987 00:00:00 +0530 Sat, 19 Feb 2011 18:28:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66017 The Tribunal allowed the appeals, setting aside the Commissioner's orders. It held that payments to foreign technicians were not taxable as salaries but as technical know-how fees or royalties, exempt under Section 9(1)(vii). The Tribunal determined no employer-employee relationship existed between BHEL and the technicians. It found the technicians eligible for exemption under the Double Taxation Avoidance Agreements with Germany and Italy, as well as under Section 10(6)(vi) of the Income-tax Act due to their short stay in India. Case-Laws Income Tax Thu, 30 Apr 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66017