https://www.taxtmi.com/caselaws?id=362359 Pure reimbursement of salary-linked and incidental expenses for a seconded employee, unsupported by any service agreement and not arising from the assessee's business of rendering services, did not constitute fees for technical services under section 9(1)(vii) or Article 12(4) of the India-Singapore DTAA, so the receipt was not taxable in India. Where the amount was subject to withholding tax under section 195, interest under section 234B could not be levied on the non-resident recipient for any advance-tax shortfall. The Revenue's additions were therefore unsustainable. en-us Thu, 21 Jun 2018 00:00:00 +0530 Sat, 23 Jun 2018 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362359 Pure reimbursement of salary-linked and incidental expenses for a seconded employee, unsupported by any service agreement and not arising from the assessee's business of rendering services, did not constitute fees for technical services under section 9(1)(vii) or Article 12(4) of the India-Singapore DTAA, so the receipt was not taxable in India. Where the amount was subject to withholding tax under section 195, interest under section 234B could not be levied on the non-resident recipient for any advance-tax shortfall. The Revenue's additions were therefore unsustainable. Case-Laws Income Tax Thu, 21 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362359