No TDS on Seconded Employee Salary Reimbursement: ITAT Bangalore

DCIT Vs Applied Materials India Private Limited (ITAT Bangalore) Revenue filed appeals against  CIT(A)’s order deleting the demand raised u/s 201(1) & 201(1A) for alleged non-deduction of TDS on salary reimbursements made by Assessee to its U.S.-based parent for seconded employees.  ITAT upheld  CIT(A)’s findings & dismissed all four appeals. Applied Materials India Pvt. Ltd. is a wholly-owned Indian subsidiary of a U.S. company. During a survey u/s 133A, it was found that Assessee reimbursed the salary of seconded employees (sent from its US parent) without TDS u/s 195...