https://www.taxtmi.com/caselaws?id=15420 Where the Tribunal found as a fact that employment services were rendered in France, article XIV(1) of the India-France DTAA allowed salary taxation only in the state where the services were performed, and section 90(2) of the Income-tax Act, 1961 gave effect to the more beneficial treaty terms. On that basis, remuneration for services rendered in France could not be taxed in India, and the proposed question did not constitute a referable question of law. The applications for reference were therefore rejected. en-us Thu, 28 Jan 1999 00:00:00 +0530 Thu, 06 Aug 2009 13:58:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15420 Where the Tribunal found as a fact that employment services were rendered in France, article XIV(1) of the India-France DTAA allowed salary taxation only in the state where the services were performed, and section 90(2) of the Income-tax Act, 1961 gave effect to the more beneficial treaty terms. On that basis, remuneration for services rendered in France could not be taxed in India, and the proposed question did not constitute a referable question of law. The applications for reference were therefore rejected. Case-Laws Income Tax Thu, 28 Jan 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15420