https://www.taxtmi.com/caselaws?id=277138 The High Court upheld the Tribunal's decision that payments made by the Respondent Company to Marks & Spencer's PLC London were not subject to tax deduction at source. The Court agreed that the payments were reimbursement for salary expenditure of employees assisting in business operations, not fees for technical services under the Double Tax Avoidance Agreement. The Tribunal's analysis of the service agreement and nature of services provided supported this conclusion, leading to the dismissal of the Revenue's appeal. The Court found no legal error in the Tribunal's decision and affirmed the Commissioner's order, ending the legal proceedings. en-us Wed, 03 May 2017 00:00:00 +0530 Tue, 27 Nov 2018 09:53:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277138 The High Court upheld the Tribunal's decision that payments made by the Respondent Company to Marks & Spencer's PLC London were not subject to tax deduction at source. The Court agreed that the payments were reimbursement for salary expenditure of employees assisting in business operations, not fees for technical services under the Double Tax Avoidance Agreement. The Tribunal's analysis of the service agreement and nature of services provided supported this conclusion, leading to the dismissal of the Revenue's appeal. The Court found no legal error in the Tribunal's decision and affirmed the Commissioner's order, ending the legal proceedings. Case-Laws Income Tax Wed, 03 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277138