https://www.taxtmi.com/caselaws?id=247227 Payments under the secondment arrangement were treated as consideration for services, not mere salary reimbursement, because the foreign entities remained the employers, supplied the secondees, and continued to bear employment-related obligations. The arrangement constituted fees for technical services under the India-UK treaty and satisfied the make-available test under the India-Canada treaty, giving the foreign entities a service permanent establishment in India. The amounts therefore accrued as income to the overseas entities and were taxable in India, so the Indian payer was required to deduct tax at source under section 195. The writ petition failed and the advance ruling was sustained. en-us Fri, 25 Apr 2014 00:00:00 +0530 Fri, 19 Jun 2026 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247227 Payments under the secondment arrangement were treated as consideration for services, not mere salary reimbursement, because the foreign entities remained the employers, supplied the secondees, and continued to bear employment-related obligations. The arrangement constituted fees for technical services under the India-UK treaty and satisfied the make-available test under the India-Canada treaty, giving the foreign entities a service permanent establishment in India. The amounts therefore accrued as income to the overseas entities and were taxable in India, so the Indian payer was required to deduct tax at source under section 195. The writ petition failed and the advance ruling was sustained. Case-Laws Income Tax Fri, 25 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247227