https://www.taxtmi.com/caselaws?id=401771 Under a secondment arrangement, reimbursement of costs paid to a foreign entity was not treated as fees for technical services where the deputed personnel worked under the assessee's control, direction and supervision. The court held that the reimbursement retained the character of cost recovery, not consideration for technical services, so it was not chargeable under section 9(1)(vii). As a result, no obligation arose to deduct tax at source under section 195, and the assessee could not be treated as an assessee in default under sections 201(1) and 201(1A). The foreign decision relied on by the revenue was distinguished because permanent establishment was not in issue. en-us Tue, 01 Dec 2020 00:00:00 +0530 Mon, 11 Aug 2025 18:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401771 Under a secondment arrangement, reimbursement of costs paid to a foreign entity was not treated as fees for technical services where the deputed personnel worked under the assessee's control, direction and supervision. The court held that the reimbursement retained the character of cost recovery, not consideration for technical services, so it was not chargeable under section 9(1)(vii). As a result, no obligation arose to deduct tax at source under section 195, and the assessee could not be treated as an assessee in default under sections 201(1) and 201(1A). The foreign decision relied on by the revenue was distinguished because permanent establishment was not in issue. Case-Laws Income Tax Tue, 01 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401771