In a recent ruling, the Income Tax Appellate Tribunal, Delhi (“Tribunal”) while differentiating the rulings in Centrica India Offshoreand Northern Operating Systems ruled that reimbursement of salaries of the ex-patriate employees of the Indian company to its foreign parent under a salary reimbursement agreement cannot be considered as Fees for Technical Services (“FTS”) and hence… Continue reading SALARY REIMBURSEMENT NOT SUBJECT TO WITHHOLDING TAX AS FEES FOR TECHNICAL SERVICES: RULES TRIBUNAL