2005 (11) TMI 25 - SUPREME COURT

Non-resident - appellant has filed these appeals as the agent of its employees who are the assessees in the present case. The appellant itself is a company which was incorporated in Panama - whether the salary of the employees of the appellant payable for field breaks outside India would be subjected to tax under section 9(1) (ii) read with the Explanation thereto - held that the 1999 Explanation would "not apply to the assessment years in question.