https://www.taxtmi.com/caselaws?id=751617 Salary received in India by a non-resident for employment actually exercised in Australia was treated as not taxable in India because the services were rendered wholly outside India and salary income is chargeable only when earned in India under sections 5, 9 and 15 of the Income-tax Act, 1961. Article 15(1) of the India-Australia DTAA, read with section 90, was applied to give the assessee the more beneficial treaty exemption. The later or absent tax residency certificate did not defeat treaty relief where foreign residency and taxation were otherwise shown. en-us Fri, 12 Apr 2024 00:00:00 +0530 Mon, 05 Jan 2026 11:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751617 Salary received in India by a non-resident for employment actually exercised in Australia was treated as not taxable in India because the services were rendered wholly outside India and salary income is chargeable only when earned in India under sections 5, 9 and 15 of the Income-tax Act, 1961. Article 15(1) of the India-Australia DTAA, read with section 90, was applied to give the assessee the more beneficial treaty exemption. The later or absent tax residency certificate did not defeat treaty relief where foreign residency and taxation were otherwise shown. Case-Laws Income Tax Fri, 12 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751617