Reimbursement of salary cost of high level managerial personal can be treated as FTS

Brief Facts and Question of Law:  Brief Facts of the Assessee: The assessee is an Indian company engaged in the business of ownership and operation of supermarket chain in India. The assessee entered into an agreement of secondment of few employees with a Hong Kong based company M/s Diary Farm Company Ltd., (herewith “DFCL”). As per the said agreement, DFCL deputed its 5 employees to India, to whom the salary was paid by DFCL which was reimbursed to DFCL by the Assessee. DFCL, withheld tax on the said salary under section 192 of the Income Tax Act, 1961 (herewith “the Act”). The asses...