https://www.taxtmi.com/highlights?id=99191 Reimbursement of salary cost for seconded employees was not taxable as fees for technical services where the secondees worked under the control of the Indian entity and the payment contained no separate service element. Applying the earlier ruling in the group concern case, the ITAT found no material factual distinction for the year under consideration and treated the receipt as falling within the employer-employee salary exclusion. The addition made on that basis was deleted. The challenge to the validity of the assessment order was not pressed and was therefore not admitted. en-us Mon, 27 Apr 2026 08:21:49 +0530 Mon, 27 Apr 2026 08:21:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99191 Reimbursement of salary cost for seconded employees was not taxable as fees for technical services where the secondees worked under the control of the Indian entity and the payment contained no separate service element. Applying the earlier ruling in the group concern case, the ITAT found no material factual distinction for the year under consideration and treated the receipt as falling within the employer-employee salary exclusion. The addition made on that basis was deleted. The challenge to the validity of the assessment order was not pressed and was therefore not admitted. Highlights Income Tax Mon, 27 Apr 2026 08:21:49 +0530 https://www.taxtmi.com/highlights?id=99191