No withholding from salary reimbursed to foreign employer for seconded employee if assessee was econ

IT/ILT : Where a UK based company having placed few of its employees at disposal of assessee-company, cross-charged salaries paid to those employees from assessee, in view of fact that reimbursement of said expenses did not involve any profit element, no income chargeable to tax accrued to foreign company in India and, thus, assessee was not required to deduct tax at source while reimbursing salary payments