Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Taxability of salary income earned by non-residents from Indian companies. In this Judgement, it was determined that under Section 9(1)(ii) of the Income Tax Act, salary income is taxable in India if earned in India. However, it was clarified that if the services are rendered outside India, the salary income cannot be taxed in India. - The Tribunal analyzed the definition of salary under Section 15 of the Income Tax Act, which includes salary due from an employer or paid/allowed to the employee. Considering the scope of total income under Section 5, the ITAT concluded that no taxability arises on salary/allowances received by the assessee as they were earned outside India.
Taxability of salary income earned by non-residents from Indian companies. In this Judgement, it was determined that under Section 9(1)(ii) of the Income Tax Act, salary income is taxable in India if earned in India. However, it was clarified that if the services are rendered outside India, the salary income cannot be taxed in India. - The Tribunal analyzed the definition of salary under Section 15 of the Income Tax Act, which includes salary due from an employer or paid/allowed to the employee. Considering the scope of total income under Section 5, the ITAT concluded that no taxability arises on salary/allowances received by the assessee as they were earned outside India.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
