https://www.taxtmi.com/caselaws?id=468268 Reimbursement of salary cost for seconded expatriate personnel was not chargeable as Fees for Technical Services where the expatriates worked under the Indian entity's control and supervision, tax had been deducted on the salary payments, and the cross-charge reflected only employee cost without an independent managerial, technical or consultancy service element. The Tribunal followed its earlier year's factual finding on the same arrangement, and the revenue's substance-over-form argument did not alter that position. The addition was deleted in favour of the assessee. en-us Tue, 22 Apr 2025 00:00:00 +0530 Fri, 24 Apr 2026 19:49:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468268 Reimbursement of salary cost for seconded expatriate personnel was not chargeable as Fees for Technical Services where the expatriates worked under the Indian entity's control and supervision, tax had been deducted on the salary payments, and the cross-charge reflected only employee cost without an independent managerial, technical or consultancy service element. The Tribunal followed its earlier year's factual finding on the same arrangement, and the revenue's substance-over-form argument did not alter that position. The addition was deleted in favour of the assessee. Case-Laws Income Tax Tue, 22 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468268