https://www.taxtmi.com/caselaws?id=66045 Payments made by an Indian company to foreign collaborators for deputing technicians were treated as fees for technical services, not salary, where the technicians remained employed by their foreign principals and no employer-employee relationship existed with the Indian company. The nature of the collaboration agreement was decisive, and the receipts were not taxable as salary in the hands of the technicians. On that basis, the Explanation to Section 9(1)(ii) did not apply to characterise the amounts as salary income. en-us Mon, 21 Aug 1989 00:00:00 +0530 Mon, 21 Feb 2011 10:42:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66045 Payments made by an Indian company to foreign collaborators for deputing technicians were treated as fees for technical services, not salary, where the technicians remained employed by their foreign principals and no employer-employee relationship existed with the Indian company. The nature of the collaboration agreement was decisive, and the receipts were not taxable as salary in the hands of the technicians. On that basis, the Explanation to Section 9(1)(ii) did not apply to characterise the amounts as salary income. Case-Laws Income Tax Mon, 21 Aug 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66045