Court Rules No Tax Deduction at Source Required for Reimbursements to Non-Resident u/ss 195 and 192.

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....TDS u/s 195 r.w.s. 192 - salary costs of a seconded employee - The employees in their capacity as employees of the assessee had to control and supervise the activities of Msource India Pvt. Ltd. Therefore, the assessee for all practical purposes has to be treated as employer of the seconded employees. There is no obligation in law for deduction of tax at source on payments made for reimbursement of costs incurred by a non resident enterprise and therefore, the amount paid by the assessee was not to suffer tax deducted at source under Section 195 - AT....