Secondment of employee by group Co. to Indian affiliate for managerial services constitutes its serv

IT/ILT: Where in terms of licence agreement entered into between assessee, a UK based company, and its Indian group concern, certain employees were seconded to Indian company to render services relating to manufacturing of Excavator loader in India, in view of fact that seconded employees furnished services including managerial services for a period of more than 90 days during relevant assessment years, Assessing Officer rightly concluded that service PE of assessee was established in India in t