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2015 (12) TMI 912 - SC ORDERApex Court dismissed the appeal of the assessee wherein HC has decided the issue against the assessee i.e Whether the secondment of employees by BSTL and DEML, the overseas entities, falls within Article 12 of the India-Canada and Article 13 of the India-UK DTAAs – High Court in this case [2014 (5) TMI 154 - DELHI HIGH COURT] had uphold the order of AAR and observed that, The nomenclature or lesser-than-expected amount charged for such services cannot change the nature of the services - once it is established that there was a provision of services, the payment made may indeed be payment for services - which may be deducted in accordance with law - or reimbursement for costs incurred – thus, the ruling of AAR is upheld – Decided against Assessee.
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