Held that that the facts were identical to the facts for the AY 2013-14 for which the Tribunal had held that since the employees deputed by the assessee were high level technical executives and rendered highly technical services to the Indian company, the payments for such services would fall within the ambit of fee for technical services Merely because the assessee had deducted tax at source that would not change the colour of the transaction. Thus, A.O. was justified in its order. (AY. 2015-16, 2017-18)
Panasonic Holdings Corporation v Dy. CIT (2023)101 ITR 5 (SN.)(Delhi) (Trib)
S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services – Reimbursement of salaries paid to employees-Employees were high level technical executives-Payments fell under technical services-Tax deducted at source not relevant-Payment taxable. [Explanation. 2]