https://www.taxtmi.com/caselaws?id=6164 SC allowed the appeals and set aside the HC decision, holding that salary paid to non-resident employees for field breaks in the U.K. was not "earned in India" under section 9(1)(ii) for the assessment years in question. The Court found the 1983 Explanation altered the judicial meaning of "earned in India" only prospectively and could not be applied retrospectively; the substituted 1999 Explanation likewise did not govern those years. On the facts, pay for U.K. field breaks did not constitute salary for service rendered in India and was not taxable under section 9(1)(ii). en-us Thu, 17 Nov 2005 00:00:00 +0530 Fri, 07 Aug 2026 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6164 SC allowed the appeals and set aside the HC decision, holding that salary paid to non-resident employees for field breaks in the U.K. was not "earned in India" under section 9(1)(ii) for the assessment years in question. The Court found the 1983 Explanation altered the judicial meaning of "earned in India" only prospectively and could not be applied retrospectively; the substituted 1999 Explanation likewise did not govern those years. On the facts, pay for U.K. field breaks did not constitute salary for service rendered in India and was not taxable under section 9(1)(ii). Case-Laws Income Tax Thu, 17 Nov 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6164