https://www.taxtmi.com/caselaws?id=272203 Salary paid to a non-resident for employment services rendered wholly in the United States was not taxable in India, because taxability depended on the place where the services were actually performed. The fact that the amount was routed through an Indian entity and subject to deduction at source in India was immaterial when the underlying employment activity occurred outside India. Article 16(1) of the India-USA Double Taxation Avoidance Agreement applied on the basis of the service location, and the assessee was entitled to treaty protection. en-us Fri, 22 Jan 2016 00:00:00 +0530 Tue, 01 Mar 2016 11:41:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=272203 Salary paid to a non-resident for employment services rendered wholly in the United States was not taxable in India, because taxability depended on the place where the services were actually performed. The fact that the amount was routed through an Indian entity and subject to deduction at source in India was immaterial when the underlying employment activity occurred outside India. Article 16(1) of the India-USA Double Taxation Avoidance Agreement applied on the basis of the service location, and the assessee was entitled to treaty protection. Case-Laws Income Tax Fri, 22 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=272203