Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
Income accrued in India - Characterization of income - 'Salary' or 'Profit in lieu of Salary' OR 'Business income' - The amount paid to the employees under the non compete agreement is covered by the expression 'salary / profits in lieu of salary', which is not taxable in India in view of Article 16 of DTAA.
Income accrued in India - Characterization of income - 'Salary' or 'Profit in lieu of Salary' OR 'Business income' - The amount paid to the employees under the non compete agreement is covered by the expression 'salary / profits in lieu of salary', which is not taxable in India in view of Article 16 of DTAA.
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