It couldn’t be held that issue was designed for tax avoidance if applicant has enquired about obligation for TDS

INCOME TAX : Where applicant-company, engaged in manufacturing of automobile and motorcycle, seconds its employees from time-to-time on long term assignment to other BMW Group entities in various countries such as Germany, Japan, etc. under terms of Reimbursement Agreement and for administrative convenience and ease of disbursement of salary of such seconded employees, applicant effects appropriate part payments to such employees in India on behalf of other BMW Group

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