https://www.taxtmi.com/caselaws?id=207776 Mere deputation of personnel to an Indian company on a hire basis did not create a permanent establishment of the foreign enterprise in India where the personnel worked under the Indian company's direction, supervision and control, and the foreign enterprise had no control over their work. The receipts were confined to reimbursement of salary costs paid in advance to the deputed personnel, so the arrangement was not treated as technical services and no taxable business profit arose in India. On those facts, the foreign enterprise had no permanent establishment in India and the reimbursement receipts were not taxable as business income. en-us Tue, 23 Feb 2010 00:00:00 +0530 Fri, 07 Jun 2013 16:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207776 Mere deputation of personnel to an Indian company on a hire basis did not create a permanent establishment of the foreign enterprise in India where the personnel worked under the Indian company's direction, supervision and control, and the foreign enterprise had no control over their work. The receipts were confined to reimbursement of salary costs paid in advance to the deputed personnel, so the arrangement was not treated as technical services and no taxable business profit arose in India. On those facts, the foreign enterprise had no permanent establishment in India and the reimbursement receipts were not taxable as business income. Case-Laws Income Tax Tue, 23 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207776