https://www.taxtmi.com/caselaws?id=248697 Salary paid to a Thailand resident for work physically performed in Thailand was held taxable only in Thailand under Article 15 of the India-Thailand DTAA. Because the employment was exercised in Thailand under the supervision and control of the Thailand company, Article 15(1) applied and Article 15(2) did not, as the employment was not exercised in India. Deduction of TDS in India did not alter the treaty position, and the addition by the tax authority was deleted. en-us Fri, 30 May 2014 00:00:00 +0530 Sat, 21 Jun 2014 10:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248697 Salary paid to a Thailand resident for work physically performed in Thailand was held taxable only in Thailand under Article 15 of the India-Thailand DTAA. Because the employment was exercised in Thailand under the supervision and control of the Thailand company, Article 15(1) applied and Article 15(2) did not, as the employment was not exercised in India. Deduction of TDS in India did not alter the treaty position, and the addition by the tax authority was deleted. Case-Laws Income Tax Fri, 30 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248697