https://www.taxtmi.com/caselaws?id=267462 The Tribunal partly allowed the appeal, upholding the CIT(A)'s decision that reimbursement of salary costs constituted 'fees for technical services' (FTS) under Section 9(1)(vii) of the Income Tax Act. The assessee was held liable under Section 201 for not withholding tax on the payments. The Tribunal remitted the issue of whether the secondment of employees constituted a service Permanent Establishment (PE) back to the Assessing Officer for further examination. en-us Wed, 28 Oct 2015 00:00:00 +0530 Thu, 05 Nov 2015 22:05:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=267462 The Tribunal partly allowed the appeal, upholding the CIT(A)'s decision that reimbursement of salary costs constituted 'fees for technical services' (FTS) under Section 9(1)(vii) of the Income Tax Act. The assessee was held liable under Section 201 for not withholding tax on the payments. The Tribunal remitted the issue of whether the secondment of employees constituted a service Permanent Establishment (PE) back to the Assessing Officer for further examination. Case-Laws Income Tax Wed, 28 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=267462