TDS not deductible on Reimbursement of Salary on Cost to Cost basis; Salary Income of recipient cannot be treated as FTS

Goldman Sachs Services Pvt. Ltd. Vs DCIT (ITAT Bangalore) Admittedly, the assessee deducted tax at source u/s.192 of the Act, on the 100% salary paid to the seconded employees, and paid the same to the credit of the Central Government. The assessee only reimbursed part of the salary cost of the seconded employee to overseas entity that has already subjected to TDS under section 192 of the Act. And therefore, at the time of making such reimbursement, to overseas entity, no taxes were deducted at source by the assessee in respect of reimbursements made as, according to the assessee, it was in th...