IBM India Not Liable for TDS on Reimbursed Salaries to IBM Philippines Without Permanent Establishment in India.

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Full Text of the Document

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....TDS liability on Reimbursement of Salary paid to the seconded employees - reimbursement made by IBM India to IBM oversees entities - Since IBM Philippines did not have Permanent Establishment (PE) in India, the receipt was not chargeable to tax in India.....