https://www.taxtmi.com/caselaws?id=306216 The Tribunal ruled in favor of the appellant, M/s. Boeing India Pvt. Ltd., in a tax dispute. The disallowance under section 40(a)(i) of the Income Tax Act for not withholding taxes on reimbursements was overturned. The Tribunal held that the reimbursements to Associated Enterprises (AEs) for salaries of expatriate employees did not constitute fees for technical services, as the employees were under the appellant's control and supervision. Additionally, the Tribunal directed a reevaluation of the determination of Arm's Length Price (ALP) for outstanding receivables from AEs, emphasizing the principle of consistency in tax assessments. Appeals for the relevant assessment years were allowed for statistical purposes. en-us Fri, 27 Nov 2020 00:00:00 +0530 Tue, 18 Apr 2023 11:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306216 The Tribunal ruled in favor of the appellant, M/s. Boeing India Pvt. Ltd., in a tax dispute. The disallowance under section 40(a)(i) of the Income Tax Act for not withholding taxes on reimbursements was overturned. The Tribunal held that the reimbursements to Associated Enterprises (AEs) for salaries of expatriate employees did not constitute fees for technical services, as the employees were under the appellant's control and supervision. Additionally, the Tribunal directed a reevaluation of the determination of Arm's Length Price (ALP) for outstanding receivables from AEs, emphasizing the principle of consistency in tax assessments. Appeals for the relevant assessment years were allowed for statistical purposes. Case-Laws Income Tax Fri, 27 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306216