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2010 (2) TMI 807 - AT - Income TaxWhether fees received for deputing two persons to India as a business profit in as much as the assessee should be considered as a person having permanent establishment in India or not. - Held that:- the American company has provided is selecting and offering personnel to work under the control and supervision of the assessee in India. It is not a part of any technical services to be rendered by the assessee to the Indian company. The deputed persons are for all practical purposes employees of the Indian company. They carry out work allotted to them by The Indian company. Assessee has no control over the activities or the work to be performed by the deputed persons. there is no income in reimbursement of the salary of the deputed employees paid by the assessee. decided in favour of Assessee.
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