https://www.taxtmi.com/caselaws?id=189754 Employment remuneration of a U.S. resident was taxable only in the State of residence under Article 16(2) of the India-U.S. DTAA. The employee's brief presence in India satisfied the 183-day condition, remuneration was paid and ultimately borne by the foreign employer, and amounts initially paid by an Indian entity were reimbursed. Because the remuneration was not borne by a permanent establishment or fixed base in India, the treaty exception to source-State taxation applied, and the salary was not taxable in India. en-us Mon, 18 Jan 1999 00:00:00 +0530 Thu, 19 Jan 2017 16:16:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189754 Employment remuneration of a U.S. resident was taxable only in the State of residence under Article 16(2) of the India-U.S. DTAA. The employee's brief presence in India satisfied the 183-day condition, remuneration was paid and ultimately borne by the foreign employer, and amounts initially paid by an Indian entity were reimbursed. Because the remuneration was not borne by a permanent establishment or fixed base in India, the treaty exception to source-State taxation applied, and the salary was not taxable in India. Case-Laws Income Tax Mon, 18 Jan 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189754