Being aggrieved, the Department filed an appeal before the Hon’ble Apex Court. The Hon’ble Apex Court after observing that the Tribunal had passed the order on the basis of facts and circumstance of the case held that since the Tribunal is the
The Hon’ble High Court of Allahabad after observing that the Assessee obtained from its Group companies directly or by transfer of the employees, the services of expatriate employees for which the Assessee paid the salaries of the employees in India,
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