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

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