https://www.taxtmi.com/caselaws?id=21804 Exemption under section 10(6)(vii) was unavailable because the foreign technicians were found to be employees of SII, not of FACT, and the statutory employment condition with the specified Indian entity was therefore not met. Tax paid by FACT on behalf of the assessees was also not taxable as salary or perquisite under sections 15 and 17 because salary-based taxation presupposes an employer-employee relationship, which did not exist between FACT and the assessees. The exemption claim failed, but the third-party tax payment could not be assessed as salary income in the assessees' hands. en-us Sat, 27 Jul 1991 00:00:00 +0530 Tue, 01 Dec 2009 13:50:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21804 Exemption under section 10(6)(vii) was unavailable because the foreign technicians were found to be employees of SII, not of FACT, and the statutory employment condition with the specified Indian entity was therefore not met. Tax paid by FACT on behalf of the assessees was also not taxable as salary or perquisite under sections 15 and 17 because salary-based taxation presupposes an employer-employee relationship, which did not exist between FACT and the assessees. The exemption claim failed, but the third-party tax payment could not be assessed as salary income in the assessees' hands. Case-Laws Income Tax Sat, 27 Jul 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21804