https://www.taxtmi.com/caselaws?id=78908 Payments made to a foreign parent company for a deputed employee's remuneration were treated as salary reimbursement where the amount was recovered at cost without any mark-up, had consistently been reflected as salary reimbursement in earlier years, and tax was deducted under the salary provisions. On those facts, the payment did not fall within fees for technical services under the Act. The Delhi HC noted that the Tribunal had already accepted the same characterisation for an earlier year on identical facts, and the payment was therefore rightly assessed as reimbursement of salary, not technical service fees. en-us Mon, 13 Sep 2010 00:00:00 +0530 Sun, 06 Feb 2011 02:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=78908 Payments made to a foreign parent company for a deputed employee's remuneration were treated as salary reimbursement where the amount was recovered at cost without any mark-up, had consistently been reflected as salary reimbursement in earlier years, and tax was deducted under the salary provisions. On those facts, the payment did not fall within fees for technical services under the Act. The Delhi HC noted that the Tribunal had already accepted the same characterisation for an earlier year on identical facts, and the payment was therefore rightly assessed as reimbursement of salary, not technical service fees. Case-Laws Income Tax Mon, 13 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=78908