https://www.taxtmi.com/caselaws?id=436007 Pure reimbursement of seconded employee salary and related costs on a cost-to-cost basis, without markup and with the employee under the Indian entity's control, was not taxable as fees for technical services or fees for included services because no profit element or make available requirement was satisfied. The Assessing Officer's fresh finding of a service permanent establishment was set aside as it went beyond the limited scope of remand. Interest under section 234B was treated as consequential and followed the deletion of the substantive addition. en-us Wed, 29 Mar 2023 00:00:00 +0530 Thu, 30 Mar 2023 13:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436007 Pure reimbursement of seconded employee salary and related costs on a cost-to-cost basis, without markup and with the employee under the Indian entity's control, was not taxable as fees for technical services or fees for included services because no profit element or make available requirement was satisfied. The Assessing Officer's fresh finding of a service permanent establishment was set aside as it went beyond the limited scope of remand. Interest under section 234B was treated as consequential and followed the deletion of the substantive addition. Case-Laws Income Tax Wed, 29 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436007