Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Salary earned by a Vietnam tax resident for employment exercised and services rendered in Vietnam qualifies for exemption in India under Article 16(1) of the India-Vietnam DTAA, read with section 90. Taxability depends on where employment is exercised and services are performed, rather than on the continued use of an Indian payroll, payment into an Indian bank account, or tax deducted at source. On that basis, remuneration for Vietnam-based employment does not accrue or arise in India under the domestic salary-tax provisions, and the claimed treaty exemption applies.
Salary earned by a Vietnam tax resident for employment exercised and services rendered in Vietnam qualifies for exemption in India under Article 16(1) of the India-Vietnam DTAA, read with section 90. Taxability depends on where employment is exercised and services are performed, rather than on the continued use of an Indian payroll, payment into an Indian bank account, or tax deducted at source. On that basis, remuneration for Vietnam-based employment does not accrue or arise in India under the domestic salary-tax provisions, and the claimed treaty exemption applies.
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