Court Rules Cost-to-Cost Reimbursements for Seconded EY India Employees Not Fees for Technical Services; No Double Taxation.

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....Fees for Technical Services [FTS] - Receipt of Cost-to-cost reimbursements on account of secondment of employees - seconded personnel are employees of EY India firms - cost to cost reimbursement on account of secondment of employees cannot be treated as FTS - The income has been taxed as salary in their respective hands - Therefore, the very same amount could not, in law, be subjected twice - AT....