The assesee made reimbursement of salaries to deputed expatriate employees . The assessee made an application under section 195 of the Act to obtain  a ‘Nil’ TDS certificate on such reimbursement of salaries . The application was rejected . On writ the Court held that  the assessee issues the appointment , letter  the employees report to the assessee and the assessee has the power to terminate the services . Thus for the purpose of limited  finding under section 195 of the Act  the assessee can be said to be the employer . Accordingly the Revenue is not justified  in rejecting the application filed  by the assessee for the grant of ‘Nil’ TDS certificate .  ( WP.No. 3619 of 2021 dt . 24 -6 2022 )