https://www.taxtmi.com/caselaws?id=18607 Foreign technicians' remuneration was treated as exempt from Indian tax under article 15 of the India-Czechoslovakia double taxation treaty because they were non-residents present in India for less than 183 days, the payments were in substance made on behalf of a non-resident employer, and the employer had no permanent establishment in India. On those facts, article 15(2) applied and Indian taxation was barred. The challenge to tax paid on behalf of the technicians also failed once treaty exemption was accepted, and the assessments could not stand. en-us Tue, 05 Dec 1995 00:00:00 +0530 Fri, 30 Oct 2009 17:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18607 Foreign technicians' remuneration was treated as exempt from Indian tax under article 15 of the India-Czechoslovakia double taxation treaty because they were non-residents present in India for less than 183 days, the payments were in substance made on behalf of a non-resident employer, and the employer had no permanent establishment in India. On those facts, article 15(2) applied and Indian taxation was barred. The challenge to tax paid on behalf of the technicians also failed once treaty exemption was accepted, and the assessments could not stand. Case-Laws Income Tax Tue, 05 Dec 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18607