Salary earned by a Vietnam tax resident for employment exercised...

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.