Revenue Must Prove Foreign Assessee's Permanent Establishment in India; Salary Reimbursement Not Technical Service Fees.

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....Existence of PE - addition on account of salary reimbursement cost treated as fee for technical services - the burden of proving that the foreign assessee has a PE in India and consequently it has to be taxed on the business generated by such PE is initially on the Revenue. - There will be no income attributable to the PE. - AT....