MORGAN STANLEY ASIA ( SINGAPORE) PTE.,MUMBAI vs. DDIT I(IT) 4(1), MUMBAI
In the result, the appeals of the assessee are party allowed
ITA 4365/MUM/2012[2007-08]Status: DisposedITAT Mumbai06 Jul 2018AY 2007-08
Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am
For Appellant: Sunil M. Lala &For Respondent: Saurabh Deshpande, DR
Section 143(3)Section 144Section 9(1)(vii)
…of FTS but as salary in the hands of the deputed employee only. For this, first we will place reliance on the decision of coordinate bench of this Tribunal in the case of Additional Director of Income Tax (IT) Vs. Mark & Spencer Reliance India (P) Ltd. (2013) 38 Taxmann.com 190 (Mumbai – Trib.). “4.7 The present case is a case of part reimbursement of expenses and therefore there is no income element present in part reimbursement. The services rendered by the four persons deputed to the appellant are assistance in management and set up of business, assistance in property selection and evaluation and leading the r…
