https://www.taxtmi.com/caselaws?id=397861 Reimbursement of salary paid to non-resident employees for services rendered at head offices outside India was held not taxable in India because section 9(1)(ii) applies only where salary is earned for services rendered in India. The attempt to apply section 9(1)(i) was rejected as misplaced. The applicable tax treaties treated salary of a non-resident as taxable where the employment is exercised, and because the employment was exercised outside India, the treaty position prevailed under section 90(2). The reimbursement was therefore not liable to disallowance under section 40(a)(iii). en-us Fri, 20 Mar 2020 00:00:00 +0530 Mon, 31 Aug 2020 18:06:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=397861 Reimbursement of salary paid to non-resident employees for services rendered at head offices outside India was held not taxable in India because section 9(1)(ii) applies only where salary is earned for services rendered in India. The attempt to apply section 9(1)(i) was rejected as misplaced. The applicable tax treaties treated salary of a non-resident as taxable where the employment is exercised, and because the employment was exercised outside India, the treaty position prevailed under section 90(2). The reimbursement was therefore not liable to disallowance under section 40(a)(iii). Case-Laws Income Tax Fri, 20 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=397861