https://www.taxtmi.com/caselaws?id=64065 The tribunal dismissed the revenue's appeals, ruling that off-period salary paid outside India to non-resident foreign expatriate employees was not taxable under section 9(1)(ii) of the Income-tax Act, 1961, prior to the Finance Act, 1999 amendment. The tribunal held that the amendment was prospective, not retrospective, as it broadened the section's scope by adding a new income item. The court emphasized that deeming provisions must be strictly construed, following precedents that clarifications expanding a section's scope cannot have retrospective effect unless explicitly stated by the legislature. en-us Mon, 24 Feb 2003 00:00:00 +0530 Thu, 03 Feb 2011 15:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64065 The tribunal dismissed the revenue's appeals, ruling that off-period salary paid outside India to non-resident foreign expatriate employees was not taxable under section 9(1)(ii) of the Income-tax Act, 1961, prior to the Finance Act, 1999 amendment. The tribunal held that the amendment was prospective, not retrospective, as it broadened the section's scope by adding a new income item. The court emphasized that deeming provisions must be strictly construed, following precedents that clarifications expanding a section's scope cannot have retrospective effect unless explicitly stated by the legislature. Case-Laws Income Tax Mon, 24 Feb 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64065