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Secondment of employees cannot be considered as Fee for Technical Services

Where a company has a person seconded from a foreign AE as an employee, and employer employee relationship exist between them, amount paid to the AE cannot be considered as Fee for Technical Services , but would be considered as ‘Salary – PS : The post is an update of judicial developments. Viewers should consider alternate decision for and against before arriving at a tax position. All views on the issue are welcome.

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