https://www.taxtmi.com/caselaws?id=776025 Cost-to-cost reimbursement of salary for seconded employees deployed in India was held not to constitute fees for technical services, because the payment reflected deputation reimbursement rather than consideration for independent technical services. Amounts received for professional services were also held not taxable as fees for included services, since Article 15(2) of the India-USA DTAA is not limited to services rendered by members of a formal professional body and the make available condition under Article 12(4)(b) was not met. On both issues, the receipts were outside the relevant taxing provisions and the tax additions were deleted. en-us Thu, 31 Jul 2025 00:00:00 +0530 Mon, 04 Aug 2025 08:28:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776025 Cost-to-cost reimbursement of salary for seconded employees deployed in India was held not to constitute fees for technical services, because the payment reflected deputation reimbursement rather than consideration for independent technical services. Amounts received for professional services were also held not taxable as fees for included services, since Article 15(2) of the India-USA DTAA is not limited to services rendered by members of a formal professional body and the make available condition under Article 12(4)(b) was not met. On both issues, the receipts were outside the relevant taxing provisions and the tax additions were deleted. Case-Laws Income Tax Thu, 31 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776025