https://www.taxtmi.com/caselaws?id=795985 Reimbursement of expatriate employee costs was not taxable as fees for technical services where the Indian associated enterprise exercised control and supervision over the seconded employees and was their real and economic employer during secondment. It paid their salaries, withheld applicable salary tax, and the employees offered that income to tax. As the reimbursement reflected actual salary cost without an income element, and no evidence showed that the Japanese assessee rendered managerial, technical, or consultancy services through the employees, contractual labels could not alter the substantive arrangement. The addition was therefore deleted. en-us Wed, 22 Apr 2026 00:00:00 +0530 Thu, 30 Jul 2026 08:52:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795985 Reimbursement of expatriate employee costs was not taxable as fees for technical services where the Indian associated enterprise exercised control and supervision over the seconded employees and was their real and economic employer during secondment. It paid their salaries, withheld applicable salary tax, and the employees offered that income to tax. As the reimbursement reflected actual salary cost without an income element, and no evidence showed that the Japanese assessee rendered managerial, technical, or consultancy services through the employees, contractual labels could not alter the substantive arrangement. The addition was therefore deleted. Case-Laws Income Tax Wed, 22 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795985