Secondment of employees by Foreign Co held to be Service PE and not taxable as Fees for Technical Service
MORGAN STANLEY INTERNATIONAL INCORPORATED VS DDIT,MUMBAI ITAT,ITA NO. 6882/MUM/2011 ISSUE INVOLVED :- Whether secondment of employees to India by assessee to render their services to Indian subsidiary companies, would constitute assessee’s service PE in India to be taxable in terms of Article 7 or the salary cost of said employees… Read More »