https://www.taxtmi.com/caselaws?id=340660 In a secondment arrangement, salary and related payments labelled as reimbursement were treated by substance as consideration for managerial and technical services, so they constituted fees for technical services and were chargeable to tax in India under section 9(1)(vii) and the treaty provision. The nomenclature of reimbursement was not decisive because the agreement, the secondees' status, and the compensation structure showed provision of services through the seconded personnel. The dispute resolution panel also had jurisdiction to enhance the total income when deciding objections that squarely raised the taxability of those receipts, and its enhancement was within its authority. en-us Fri, 10 Mar 2017 00:00:00 +0530 Fri, 24 Mar 2017 12:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=340660 In a secondment arrangement, salary and related payments labelled as reimbursement were treated by substance as consideration for managerial and technical services, so they constituted fees for technical services and were chargeable to tax in India under section 9(1)(vii) and the treaty provision. The nomenclature of reimbursement was not decisive because the agreement, the secondees' status, and the compensation structure showed provision of services through the seconded personnel. The dispute resolution panel also had jurisdiction to enhance the total income when deciding objections that squarely raised the taxability of those receipts, and its enhancement was within its authority. Case-Laws Income Tax Fri, 10 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=340660