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The Delhi High Court has departed from established precedent by ruling that expatriate secondees remain under the control of their seconding entity and retain employment liens, even while working for Indian entities. In Ernst and Young U.S. LLP, the court held that cost-to-cost salary reimbursements for seconded employees constitute Fee for Technical Services under Indian tax law and the India-US tax treaty, overturning the Income Tax Appellate Tribunal's decision that had favored the taxpayer.