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    <title>2023 (6) TMI 1270 - ITAT DELHI</title>
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    <description>A resident assessee&#039;s bonus received from a Singapore employer was treated as taxable in India because it was received during the relevant year and formed part of salary income, even though it related to earlier services rendered in Singapore. The India-Singapore treaty was noted to permit taxation of employment remuneration in the state where the employment is exercised. On foreign tax credit, the tax paid in Singapore on the same salary and bonus income was held not to be subject to an artificial percentage restriction, as no such limitation was supported by the Act or treaty. Full foreign tax credit was therefore allowable for the foreign tax actually paid on that income.</description>
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      <link>https://www.taxtmi.com/caselaws?id=439696</link>
      <description>A resident assessee&#039;s bonus received from a Singapore employer was treated as taxable in India because it was received during the relevant year and formed part of salary income, even though it related to earlier services rendered in Singapore. The India-Singapore treaty was noted to permit taxation of employment remuneration in the state where the employment is exercised. On foreign tax credit, the tax paid in Singapore on the same salary and bonus income was held not to be subject to an artificial percentage restriction, as no such limitation was supported by the Act or treaty. Full foreign tax credit was therefore allowable for the foreign tax actually paid on that income.</description>
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