Reimbursements for seconded employees did not constitute FTS: Karnataka HC

Director of Income-Tax Vs Abbey Business Services India Pvt. Ltd. (Karnataka High Court)

Karnataka High Court adjudicated the case of Director of Income-Tax vs. Abbey Business Services India Pvt. Ltd., concerning the applicability of tax deduction at source (TDS) on payments made to a non-resident under Section 195 of the Income Tax Act, 1961. The Revenue contended that payments made by Abbey India to Abbey UK for seconded employees constituted “fees for technical services” (FTS) under Section 9(1)(vii) and the India-UK Double Taxation Avoidance Agreement (DTAA

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