https://www.taxtmi.com/caselaws?id=394319 A Tax Residency Certificate is treated as procedural rather than an absolute precondition for claiming treaty relief under the India-Austria DTAA where residency and entitlement are otherwise established. The text also states that salary and foreign allowance for employment exercised in Austria fall within Article 15(1) and are outside Indian taxability when the assessee is non-resident in India and tax resident of Austria. It further notes that receipt in India and absence of foreign bank records do not defeat treaty relief once the place of employment and treaty conditions are proved, and that such foreign employment income is excluded from section 5(2) to the extent it arises from services rendered abroad. en-us Thu, 05 Mar 2020 00:00:00 +0530 Wed, 24 Jun 2020 14:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=394319 A Tax Residency Certificate is treated as procedural rather than an absolute precondition for claiming treaty relief under the India-Austria DTAA where residency and entitlement are otherwise established. The text also states that salary and foreign allowance for employment exercised in Austria fall within Article 15(1) and are outside Indian taxability when the assessee is non-resident in India and tax resident of Austria. It further notes that receipt in India and absence of foreign bank records do not defeat treaty relief once the place of employment and treaty conditions are proved, and that such foreign employment income is excluded from section 5(2) to the extent it arises from services rendered abroad. Case-Laws Income Tax Thu, 05 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=394319