https://www.taxtmi.com/caselaws?id=296279 Cost-to-cost reimbursement of expatriate-related social security, insurance and relocation expenses, where the personnel remained under the applicant's control and the overseas entity acted only as a facilitator, did not constitute fee for technical services and was not chargeable to tax in India in the hands of the overseas entity. A separate administrative fee paid for disbursing those amounts was treated as consideration for services falling within fee for technical services, and tax deduction at source was required under section 195. The ruling thus distinguished between mere reimbursement of obligatory employee-related outgoings and a distinct service charge. en-us Wed, 08 Jan 2020 00:00:00 +0530 Tue, 13 Jul 2021 16:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296279 Cost-to-cost reimbursement of expatriate-related social security, insurance and relocation expenses, where the personnel remained under the applicant's control and the overseas entity acted only as a facilitator, did not constitute fee for technical services and was not chargeable to tax in India in the hands of the overseas entity. A separate administrative fee paid for disbursing those amounts was treated as consideration for services falling within fee for technical services, and tax deduction at source was required under section 195. The ruling thus distinguished between mere reimbursement of obligatory employee-related outgoings and a distinct service charge. Case-Laws Income Tax Wed, 08 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296279