years is relating to deduction on account of remuneration paid to the expatriate employees outside India for the services rendered in India. Tax deducted ... paid by the head office in the current financial year to the expatriate employees rendering services in India, on the basis of the reasons stated
Lg Electronics India Pvt. Ltd., Uttar ... vs Acit, Noida on 16 September, 2022
IN THE
sent on deputation are called "employees sent on
Secondment" "Expatriate Employee" etc. The group has a standard
expatriate Agreement to regulate ... employee to another group in another country. The terms of the expatriate
Agreement dated 1.1.2002 between IBM UK and IBM India, whereby IBM
UK agreed
holding that the seconded
expatriate employees are rendering services to SIEL on behalf of
the assessee and, therefore, created a PE of SEC in India ... Korea DTAA. Ld. AO passed draft
assessment order dated 30.12.2011, holding that expatriates
employees create a PE of the assessee in India by rendering
services
grievance is that no tax was payable on remuneration of expatriates who fulfilled all the conditions of exemption in terms of Article ... assessee engaged the services of number of technicians. In respect of expatriates deputed for business operations on Jack up rig I.D.A. owned
spite of the fact that no tax waspayable on the remuneration of expatriates who fulfilled all the conditionsof exemption in terms of article ... lodging and boarding provided by ONGC on their drill ships for the expatriates as necessary conditions of deployment as perquisites for determining the tax liability
Appellant in India while relying on the
statements of expatriate employees of Honda Cars India Ltd. (HCIL)
which were inadmissible evidence in terms ... That the AO/DRP erred in coming to the conclusion that expatriate
employees working in Honda Cars India Ltd were working on behalf
1779/D/2015
Assessment year 2008-09
expatriates, gratuity liability transferred, prior period expenses,
differential amount of mark up, interest not charged from the
foreign ... Services Agreement
(MSA), addition on account of tax deposited on behalf of
expatriates and margins thereof, addition on account of expenses
incurred on behalf
following grounds of appeal:-
"1 Disallowance of salary paid overseas to expatriates of the Appellant working in
India by the Head Office ... thereon), without
appreciating that such salary paid by the HO to the expatriate employees working in
India exclusively for the Permanent Establishment
source on certain amount of emoluments paid by the appellant-company to expatriate Japanese staff, who were on short-term assignment to India. The emoluments ... employ large number of local Indians as well as large number of expatriate Japanese. The Japanese personnel are deputed to these offices from Japan
