Secondment Agreement Payments Not Classified as Technical Service Fees for TDS Purposes Due to Employee Control by Payer.

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....TDS liability - FTS - the consideration paid under the secondment agreement was not “fees for technical services” because the fact that the seconded employee was responsible and subservient to the payer (assessee) and was required to also act as officer or authorized signatory or nominee of the assessee made it inconsistent with an agreement for providing technical services - AT....