https://www.taxtmi.com/caselaws?id=236615 Reimbursement of salary and allied expenses for seconded employees was treated as non-taxable in the recipient's hands where the employees worked under the Indian company's control and tax had already been deducted under section 192 by the overseas employer; accordingly, no further deduction under section 195 arose and the related disallowance under section 40(a)(ia) was deleted. The arrangement was also not regarded as fees for technical services under section 9(1)(vii) or Article 12(4)(b) of the India-Singapore DTAA. Reimbursement of professional fees required separate examination. In transfer pricing, comparability turned on functional similarity, risk profile, and reliable segmental analysis, and the investment advisory adjustment was deleted because the assessee's comparables were functionally acceptable and the margin was treated as arm's length. en-us Fri, 30 Aug 2013 00:00:00 +0530 Tue, 20 Dec 2022 11:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236615 Reimbursement of salary and allied expenses for seconded employees was treated as non-taxable in the recipient's hands where the employees worked under the Indian company's control and tax had already been deducted under section 192 by the overseas employer; accordingly, no further deduction under section 195 arose and the related disallowance under section 40(a)(ia) was deleted. The arrangement was also not regarded as fees for technical services under section 9(1)(vii) or Article 12(4)(b) of the India-Singapore DTAA. Reimbursement of professional fees required separate examination. In transfer pricing, comparability turned on functional similarity, risk profile, and reliable segmental analysis, and the investment advisory adjustment was deleted because the assessee's comparables were functionally acceptable and the margin was treated as arm's length. Case-Laws Income Tax Fri, 30 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236615