https://www.taxtmi.com/caselaws?id=239140 Reimbursement of salary costs for seconded personnel, without any mark-up or profit element, was treated as non-taxable under the India-UK DTAA because the arrangement did not make available technical knowledge, experience, skill, know-how or processes to the assessee. The services performed through the secondees, including management, property selection, retail operations and merchandising support, therefore did not fall within fees for technical services. As the underlying salary component had already been taxed in India, no withholding-tax default arose and the payer was not liable to be treated as an assessee in default under sections 195 and 201. en-us Wed, 04 Sep 2013 00:00:00 +0530 Mon, 11 Aug 2025 18:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239140 Reimbursement of salary costs for seconded personnel, without any mark-up or profit element, was treated as non-taxable under the India-UK DTAA because the arrangement did not make available technical knowledge, experience, skill, know-how or processes to the assessee. The services performed through the secondees, including management, property selection, retail operations and merchandising support, therefore did not fall within fees for technical services. As the underlying salary component had already been taxed in India, no withholding-tax default arose and the payer was not liable to be treated as an assessee in default under sections 195 and 201. Case-Laws Income Tax Wed, 04 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239140