https://www.taxtmi.com/caselaws?id=306216 Reimbursement of salary and related costs for seconded expatriate employees was held not to constitute fees for technical services or royalty where the employees worked under the assessee's control and supervision, the salary was borne by the assessee, and tax had already been deducted under section 192; the disallowance under section 40(a)(i) was deleted. On outstanding receivables from associated enterprises, the Tribunal applied the rule of consistency and remanded the transfer pricing adjustment for fresh consideration because an earlier year on identical facts had not imputed interest. The salary reimbursement issue was decided in favour of the assessee, and the receivables issue was sent back for reconsideration. 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 Reimbursement of salary and related costs for seconded expatriate employees was held not to constitute fees for technical services or royalty where the employees worked under the assessee's control and supervision, the salary was borne by the assessee, and tax had already been deducted under section 192; the disallowance under section 40(a)(i) was deleted. On outstanding receivables from associated enterprises, the Tribunal applied the rule of consistency and remanded the transfer pricing adjustment for fresh consideration because an earlier year on identical facts had not imputed interest. The salary reimbursement issue was decided in favour of the assessee, and the receivables issue was sent back for reconsideration. Case-Laws Income Tax Fri, 27 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306216