https://www.taxtmi.com/caselaws?id=313588 A non-resident employee's salary received in India for services actually rendered in Ireland was held not taxable in India because the employment was exercised outside India and the treaty conditions under Article 15(1) of the India-Ireland DTAA were satisfied. The fact that payment was routed through an Indian entity for administrative convenience did not alter the character of the income. On the same facts, section 9(1)(ii) did not deem the salary to accrue or arise in India, since that provision applies only where services are rendered in India. The addition was deleted. en-us Wed, 14 Feb 2024 00:00:00 +0530 Mon, 22 Apr 2024 20:41:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313588 A non-resident employee's salary received in India for services actually rendered in Ireland was held not taxable in India because the employment was exercised outside India and the treaty conditions under Article 15(1) of the India-Ireland DTAA were satisfied. The fact that payment was routed through an Indian entity for administrative convenience did not alter the character of the income. On the same facts, section 9(1)(ii) did not deem the salary to accrue or arise in India, since that provision applies only where services are rendered in India. The addition was deleted. Case-Laws Income Tax Wed, 14 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313588