Salary Reimbursements Not FTS, No TDS u/s 195 on Secondment of Employees

AT & T Communication Services (India) P. Ltd. Vs DCIT (ITAT Delhi) Income Tax Appellate Tribunal (ITAT), Delhi Bench, has delivered a comprehensive ruling largely in favor of AT & T Communication Services (India) P. Ltd., setting aside several tax adjustments made by the Deputy Commissioner of Income Tax (DCIT) for assessment years 2011-12 and 2012-13. The Tribunal’s decision clarified critical aspects of transfer pricing, disallowance of statutory liabilities, and tax deduction at source (TDS) on reimbursements for seconded employees. The appeals, stemming from assessment orders...