https://www.taxtmi.com/caselaws?id=777672 Reimbursement of salary costs to an overseas group entity under a secondment arrangement was treated as a cost-to-cost recovery, not consideration for technical, managerial or consultancy services. Because tax had already been deducted on the salary component under section 192 and the payment to the foreign entity was only a reimbursement, no additional withholding tax was required under section 195. The consequential liability under section 201 therefore did not survive. The analysis relied on earlier orders in the assessee's own case and binding jurisdictional decisions. en-us Thu, 24 Jul 2025 00:00:00 +0530 Wed, 03 Sep 2025 08:19:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777672 Reimbursement of salary costs to an overseas group entity under a secondment arrangement was treated as a cost-to-cost recovery, not consideration for technical, managerial or consultancy services. Because tax had already been deducted on the salary component under section 192 and the payment to the foreign entity was only a reimbursement, no additional withholding tax was required under section 195. The consequential liability under section 201 therefore did not survive. The analysis relied on earlier orders in the assessee's own case and binding jurisdictional decisions. Case-Laws Income Tax Thu, 24 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777672