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    <title>2024 (11) TMI 865 - ITAT CHENNAI</title>
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    <description>ITAT Chennai held that salary income of a non-resident employee seconded to UK assignment was not taxable in India. The assessee, a UK tax resident who spent less than 60 days in India during AY 2020-21, was employed by Ernst Young LLP and seconded overseas. Under Article 15(1) of India-UK DTAA, salary for employment exercised in UK is taxable only in UK. The proportionate salary for Indian services was already taxed in India, while UK salary was taxed in UK without claiming foreign tax credit. CIT(A)&#039;s deletion of addition was upheld, deciding in favor of assessee.</description>
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      <description>ITAT Chennai held that salary income of a non-resident employee seconded to UK assignment was not taxable in India. The assessee, a UK tax resident who spent less than 60 days in India during AY 2020-21, was employed by Ernst Young LLP and seconded overseas. Under Article 15(1) of India-UK DTAA, salary for employment exercised in UK is taxable only in UK. The proportionate salary for Indian services was already taxed in India, while UK salary was taxed in UK without claiming foreign tax credit. CIT(A)&#039;s deletion of addition was upheld, deciding in favor of assessee.</description>
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