https://www.taxtmi.com/caselaws?id=30866 Article 20(1)(a) of the India-Korea tax treaty exempts remuneration only when it is paid by a Contracting State in respect of services rendered to that State. A government-owned or government-controlled corporation with separate corporate personality is not, by that fact alone, the State or a department of the State. The applicant failed to prove that the salary of the head of the Indian liaison office was paid directly from government funds specifically allocated for personnel expenses. Exemption was therefore denied, and the remuneration remained taxable in India. en-us Fri, 29 Aug 2008 00:00:00 +0530 Sat, 17 Sep 2011 16:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=30866 Article 20(1)(a) of the India-Korea tax treaty exempts remuneration only when it is paid by a Contracting State in respect of services rendered to that State. A government-owned or government-controlled corporation with separate corporate personality is not, by that fact alone, the State or a department of the State. The applicant failed to prove that the salary of the head of the Indian liaison office was paid directly from government funds specifically allocated for personnel expenses. Exemption was therefore denied, and the remuneration remained taxable in India. Case-Laws Income Tax Fri, 29 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=30866