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The ITAT ruled that the salary received by the assessee for an international assignment to the UK, being a resident of the UK and a non-resident of India, is not taxable in India. The Tribunal observed that the assessee had paid taxes in the UK on the salary income, and therefore, the foreign assignment salary earned by the assessee should be excluded while recomputing the income, as per Article 16(1) of the India-UK Tax Treaty.
The ITAT ruled that the salary received by the assessee for an international assignment to the UK, being a resident of the UK and a non-resident of India, is not taxable in India. The Tribunal observed that the assessee had paid taxes in the UK on the salary income, and therefore, the foreign assignment salary earned by the assessee should be excluded while recomputing the income, as per Article 16(1) of the India-UK Tax Treaty.
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