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Salary payment to seconded employees working in India not taxable as it was mere reimbursement on cost-to-cost basis

July 22, 2020[2020] 117 759 (Delhi - Trib.)/[2020] 81 ITR(T) 440 (Delhi - Trib.)

INTERNATIONAL TAXATION : Where assessee, a Singapore based company, seconded its employee to an Indian concern for carrying out business operations of its restaurant outlets in India efficiently, in view of fact that said employee worked under direct supervision and control of Indian concern and, moreover, his salary cost was reimbursed to assessee on cost to cost basis, amount so paid was not liable to tax in India as fee for technical services

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