https://www.taxtmi.com/caselaws?id=790483 A cost-to-cost reimbursement of staff salary paid by a project office to its head office, without any markup, was treated as an internal transfer within the same enterprise and not as separate income. The ITAT applied the principle that a permanent establishment and its head office are parts of one entity, so a payment between them is a payment to self and does not create an independent taxable stream. As the assessee had already offered its receipts to tax under section 44DA and the reimbursement represented actual staff cost only, the amount was not taxable as fee for technical services and the addition was deleted. en-us Thu, 23 Apr 2026 00:00:00 +0530 Sat, 25 Apr 2026 10:16:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790483 A cost-to-cost reimbursement of staff salary paid by a project office to its head office, without any markup, was treated as an internal transfer within the same enterprise and not as separate income. The ITAT applied the principle that a permanent establishment and its head office are parts of one entity, so a payment between them is a payment to self and does not create an independent taxable stream. As the assessee had already offered its receipts to tax under section 44DA and the reimbursement represented actual staff cost only, the amount was not taxable as fee for technical services and the addition was deleted. Case-Laws Income Tax Thu, 23 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790483