https://www.taxtmi.com/caselaws?id=756651 A non-resident employee's foreign assignment allowance first credited outside India was held outside Indian tax under section 5(2), because non-resident income is taxable only on receipt, deemed receipt, accrual, or deemed accrual in India. The stock option perquisite linked to services rendered outside India was also treated as outside taxable income in India. On treaty residence being established by a UK tax residency certificate, exemption under Article 16(1) of the India-UK DTAA read with section 90(2) was applied to the salary income in question. Delay in filing the appeal was condoned to permit adjudication on merits. en-us Tue, 23 Jul 2024 00:00:00 +0530 Wed, 07 Aug 2024 06:44:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756651 A non-resident employee's foreign assignment allowance first credited outside India was held outside Indian tax under section 5(2), because non-resident income is taxable only on receipt, deemed receipt, accrual, or deemed accrual in India. The stock option perquisite linked to services rendered outside India was also treated as outside taxable income in India. On treaty residence being established by a UK tax residency certificate, exemption under Article 16(1) of the India-UK DTAA read with section 90(2) was applied to the salary income in question. Delay in filing the appeal was condoned to permit adjudication on merits. Case-Laws Income Tax Tue, 23 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756651