https://www.taxtmi.com/highlights?id=95315 Reimbursements received from Indian group entities for actual salary costs of seconded employees could not be taxed as fees for technical services under section 9(1)(vii) and Article 12(4) of the India-Japan DTAA because the contracts and appointment letters established an employer-employee relationship between the secondees and the Indian entities, making the payments in substance salary and not consideration for rendering technical services; accordingly, the reimbursements were not recharacterizable as FTS and the addition was deleted, allowing the appeal. - ITAT en-us Tue, 23 Dec 2025 07:59:05 +0530 Tue, 23 Dec 2025 07:59:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95315 Reimbursements received from Indian group entities for actual salary costs of seconded employees could not be taxed as fees for technical services under section 9(1)(vii) and Article 12(4) of the India-Japan DTAA because the contracts and appointment letters established an employer-employee relationship between the secondees and the Indian entities, making the payments in substance salary and not consideration for rendering technical services; accordingly, the reimbursements were not recharacterizable as FTS and the addition was deleted, allowing the appeal. - ITAT Highlights Income Tax Tue, 23 Dec 2025 07:59:05 +0530 https://www.taxtmi.com/highlights?id=95315