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    <title>1986 (8) TMI 444 - ITAT MUMBAI</title>
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    <description>Salary earned by a non-resident seaman for services rendered mostly outside India was treated as not accruing or arising in India under section 5(2)(b) of the Income-tax Act, 1961. The decisive factor was the place where the services were performed, not the place of the employment contract or the source of payment. Because the employee remained outside India for the accounting period except for eight days, and the remuneration was earned and received outside India, the brief presence in India did not justify apportionment of the salary as Indian income. The result was that the salary was not taxable in India.</description>
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    <pubDate>Mon, 11 Aug 1986 00:00:00 +0530</pubDate>
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      <title>1986 (8) TMI 444 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=186795</link>
      <description>Salary earned by a non-resident seaman for services rendered mostly outside India was treated as not accruing or arising in India under section 5(2)(b) of the Income-tax Act, 1961. The decisive factor was the place where the services were performed, not the place of the employment contract or the source of payment. Because the employee remained outside India for the accounting period except for eight days, and the remuneration was earned and received outside India, the brief presence in India did not justify apportionment of the salary as Indian income. The result was that the salary was not taxable in India.</description>
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      <pubDate>Mon, 11 Aug 1986 00:00:00 +0530</pubDate>
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