Mumbai Tribunal rules that no Permanent Establishment arises on deputation on hire basis. Further, no income arises to recipient on reimbursement of salary costs

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...