https://www.taxtmi.com/caselaws?id=215781 Payments under a secondment arrangement were treated as taxable income of the foreign principal, not mere salary reimbursement, where the seconded employees remained on that principal's payroll, retained service benefits, and continued to be subject to its employment control. On that basis, the recipient company was required to deduct tax at source under section 195 of the Income-tax Act, 1961. For payroll processing charges, the record was insufficient to determine the substantive tax character conclusively, so no final ruling was given on chargeability; however, withholding was still required at the applicable rates, subject to the outcome of assessment proceedings. en-us Thu, 16 Aug 2012 00:00:00 +0530 Wed, 12 Dec 2012 10:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215781 Payments under a secondment arrangement were treated as taxable income of the foreign principal, not mere salary reimbursement, where the seconded employees remained on that principal's payroll, retained service benefits, and continued to be subject to its employment control. On that basis, the recipient company was required to deduct tax at source under section 195 of the Income-tax Act, 1961. For payroll processing charges, the record was insufficient to determine the substantive tax character conclusively, so no final ruling was given on chargeability; however, withholding was still required at the applicable rates, subject to the outcome of assessment proceedings. Case-Laws Income Tax Thu, 16 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215781