https://www.taxtmi.com/caselaws?id=445232 Salary received by a non-resident for services rendered outside India does not become taxable in India merely because it is credited to an NRE account. The deeming rule for salary accrual applies only when the services are rendered in India, so credit into an Indian NRE account by itself does not create Indian tax liability. CBDT Circular No. 13/2017 was treated as a beneficial clarification addressing hardship in comparable situations, and its practical application was not confined narrowly to seafarers where the employment facts were similar. On that basis, the tax addition was deleted. en-us Tue, 31 Oct 2023 00:00:00 +0530 Fri, 03 Nov 2023 14:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445232 Salary received by a non-resident for services rendered outside India does not become taxable in India merely because it is credited to an NRE account. The deeming rule for salary accrual applies only when the services are rendered in India, so credit into an Indian NRE account by itself does not create Indian tax liability. CBDT Circular No. 13/2017 was treated as a beneficial clarification addressing hardship in comparable situations, and its practical application was not confined narrowly to seafarers where the employment facts were similar. On that basis, the tax addition was deleted. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445232