https://www.taxtmi.com/caselaws?id=309196 Salary paid to a non-resident for services rendered in Switzerland was chargeable in India because the income was credited and received in India. On those facts, section 5(2)(a) applied on a receipt basis, and the argument under section 9(1)(ii) did not alter the taxability position. The treaty claim under Article 15(1) of the India-Switzerland DTAA also failed, as read with Article 23(2)(a) it was held inapplicable in the manner contended. The salary was therefore taxable in India, and exemption under the treaty was rejected. en-us Thu, 16 Nov 2017 00:00:00 +0530 Thu, 17 Aug 2023 07:45:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=309196 Salary paid to a non-resident for services rendered in Switzerland was chargeable in India because the income was credited and received in India. On those facts, section 5(2)(a) applied on a receipt basis, and the argument under section 9(1)(ii) did not alter the taxability position. The treaty claim under Article 15(1) of the India-Switzerland DTAA also failed, as read with Article 23(2)(a) it was held inapplicable in the manner contended. The salary was therefore taxable in India, and exemption under the treaty was rejected. Case-Laws Income Tax Thu, 16 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=309196