2000 (12) TMI 69

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.....---The assessee is an employee of an Italian company-Italviscose Eastern Trading S. P. A. Milan, which had entered into an agreement with South India Viscose Limited in connection with the expansion project of the latter company's pulp plant. Under the terms of that agreement out of the sums paid by the Indian company to the Italian company, the employee of the Italian company was to receive the ....

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....ing upheld the order of the Commissioner, the Revenue has brought this reference before us. On the facts as found by the Tribunal, it is amply clear that the assessee was not an employee of the Indian company, and he had not been paid any salary by the Indian company, He was a technician, who had been sent by his Italian employer pursuant to an agreement between that employer and the Indian com....