TDS U/s. 195 not applicable on Payment under Secondment if same is taxable in India as Salary

1. By way of this appeal, the assessee appellant has challenged correctness of learned CIT(A)’s order dated 10th July 2012, in the matter of assessment under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the assessment year 2009-10. 2. Grievances raised by the assessee, in substance, are against learned CIT(A)’s upholding (i) the disallowance , under section 40(a)(i), of Rs 4,54,28,424, in respect of reimbursement of payroll costs, and of Rs 16,86,463, in respect of reimbursement of related professional and legal fees, to Burt Hill Inc USA; (ii) ...