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Mumbai Tribunal rules that no Permanent Establishment arises on deputation on hire basis. Further, no income arises to recipient on reimbursement of salary costs
Case Law Details
- Case Name
- Tekmark Global Solutions LLC Vs. DDIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2003- 04
- Courts
- All ITAT, ITAT Mumbai
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Facts
Tekmark Global Solutions LLC (“Tekmark?), a tax resident of the USA, deputed its personnel to Lucent Technologies Hindustan Private Limited („Lucent India?)
As per the agreement between Tekmark and Lucent India, Tekmark to make arrangements to depute personnel based on specific requirements from Lucent India.
Deputed personnel remain on the payroll of Tekmark and related costs to be charged to Lucent India.
Such deputed personnel work under the direction, supervision and control of Lucent India
Tekmark is not responsible for the work done / action performed by such deputed personnel...
