Reimbursement for Seconded Personnel: Are Salary Costs "Fees for Technical Services" u/s 9(1)(vii) of Income Tax Act?

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....Reimbursement of salary costs of seconded personnel - whether is in the nature of ‘fees for technical services’ u/s 9(1)(vii) - TDS u/s 195 - all the payment made by the assessee to non-resident on account of FTS or royalty an chargeable to tax irrespective of any profit element in the said payment or not - AT....