Dismissing the appeal of the revenue the Court held that as per manpower supply contract, assessee manpower provider supplied commissioning engineer to Kuwait based company .Kuwaiti company paid deputation charges of US $ 5500 per month to assessee and assessee paid US $ 4000 per month to employee. While Kuwait based company would enjoy considerable supervising powers over said employee as long as employee was working for it, nevertheless, assessee-company continued to enjoy employer-employee relationship with said employee. Court held that assessee-company was not required to deduct tax in respect of payment of remuneration made to deputed employee.