No Permanent Establishment: Fees for Deputing Individuals to India Not Treated as Business Profits Due to Lack of Control.

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Full Text of the Document

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....Whether fees received for deputing two persons to India as a business profit in as much as the assessee should be considered as a person having permanent establishment in India or not - - Assessee has no control over the activities or the work to be performed by the deputed persons. there is no income in reimbursement of the salary of the deputed employees paid by the assessee..... - AT....