FTS not include consideration taxable as Salary in the hands of recipient

Alfa Laval Corporate AB Vs ACIT (International Taxation) (ITAT Pune) it is seen that the assessee has canvassed a case that the amount in question was part of the salary of certain expatriates, who were on payroll of the Indian entities and that this amount was recovered from Indian companies without any mark-up. The assessee also contended that this amount was offered to tax in India by such employees. Explanation 2 to section 9(1)(vii) provides that FTS includes any consideration for rendering managerial consultancy services etc., but does not include consideration `which would become income...