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2009 (1) TMI 19 - AUTHORITY FOR ADVANCE RULINGS
Secondment Agreement between applicant (Indian Company) & HMFICL (Korean Company) - an employee of HMFICL, were kept at the disposal of the applicant for a period of two years in order to assist the applicant in matters relating to Korean insurance business - Whether the amount paid or payable by the applicant to HMFICL under the agreement is in the nature of income accruing to M/s. HMFICL in respect of which, tax is liable to be deducted at source by the applicant u/s 195 – Held, no