Reimbursement of salary for seconded employee cannot be taxed as FTS

Juniper Networks Inc Vs ITO (ITAT Bangalore) ITAT Bangalore held that reimbursement of salary for seconded employee cannot be regarded as ‘Fee for technical services’ (FTS) under India-US Tax Treaty (DTAA). Facts- The assessee, Juniper Networks Inc. is a company headquartered in the United States. The assessee had entered into an agreement for secondment of its personnel with the Indian entity Juniper Networks India Pvt. Ltd. (henceforth Juniper India). During the year under appeal, two of the assessee’s employees were seconded to Juniper India. as Engineering Services Managers. The sala...