https://www.taxtmi.com/caselaws?id=364306 Reimbursement of salary for a seconded employee was treated as a pure salary recharge, with no profit element, and therefore fell outside fees for technical services under section 9(1)(vii). The Explanation excluding consideration taxable as salary applied because the payment represented salary cost recovered under the contractual arrangement. Under Article 12 of the India-Singapore DTAA, the services were also not shown to satisfy the make available requirement, so the amount could not be taxed as technical services in the assessee's hands. The addition was deleted, and the alternative adjustment issue was not examined. en-us Fri, 06 Jul 2018 00:00:00 +0530 Mon, 11 Aug 2025 18:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=364306 Reimbursement of salary for a seconded employee was treated as a pure salary recharge, with no profit element, and therefore fell outside fees for technical services under section 9(1)(vii). The Explanation excluding consideration taxable as salary applied because the payment represented salary cost recovered under the contractual arrangement. Under Article 12 of the India-Singapore DTAA, the services were also not shown to satisfy the make available requirement, so the amount could not be taxed as technical services in the assessee's hands. The addition was deleted, and the alternative adjustment issue was not examined. Case-Laws Income Tax Fri, 06 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=364306