https://www.taxtmi.com/caselaws?id=307262 Reimbursement of salary and related costs under an employee secondment arrangement was considered on an incorrect factual basis, as the record indicated that the Indian entity reimbursed direct wages and benefit costs under the secondment agreement and salary-related forms. The taxability of such reimbursement as fees for technical services under the Income-tax Act, 1961 and the India-Canada DTAA required examination on the correct factual matrix. The matter was therefore remanded to the Assessing Officer for fresh adjudication after reappreciation of the facts, with an opportunity of hearing to the assessee. en-us Tue, 16 Jul 2019 00:00:00 +0530 Fri, 31 Mar 2023 08:48:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307262 Reimbursement of salary and related costs under an employee secondment arrangement was considered on an incorrect factual basis, as the record indicated that the Indian entity reimbursed direct wages and benefit costs under the secondment agreement and salary-related forms. The taxability of such reimbursement as fees for technical services under the Income-tax Act, 1961 and the India-Canada DTAA required examination on the correct factual matrix. The matter was therefore remanded to the Assessing Officer for fresh adjudication after reappreciation of the facts, with an opportunity of hearing to the assessee. Case-Laws Income Tax Tue, 16 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307262