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Reimbursement of salary of seconded employees held as FTS; ITAT relies on HC’s ruling of Centrica

March 17, 2017[2017] 79 199 (Bangalore - Trib.)

IT/ILT : Where assessee, a Switzerland based company, engaged in providing operations and management services to airports, entered into an agreement with Bangalore International Airport Ltd. (BIAL) for secondment of its skilled personnel, since said personnel were having expertise in management and thus purpose of assignment was to avail managerial services of those highly qualified personnel, amount received by assessee from BIAL in terms of secondment agreement was in nature of 'fee for technical services' chargeable to tax under section 9(1)(vii) as well as under article 12 of India-Switzerland DTAA

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