https://www.taxtmi.com/caselaws?id=761879 A non-resident employee's salary attributable to services performed in the United Kingdom was held not taxable in India where the income had already been offered to tax in the UK. The treaty rule in Article 15(1) of the India-UK DTAA prevailed over the domestic charging provisions, so payment of salary in India and the continuance of the employer-employee relationship did not by themselves create Indian taxability for foreign employment income. The salary linked to work performed in India was not in issue on the same basis. The addition was deleted and that deletion was upheld. en-us Mon, 04 Nov 2024 00:00:00 +0530 Tue, 19 Nov 2024 08:40:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761879 A non-resident employee's salary attributable to services performed in the United Kingdom was held not taxable in India where the income had already been offered to tax in the UK. The treaty rule in Article 15(1) of the India-UK DTAA prevailed over the domestic charging provisions, so payment of salary in India and the continuance of the employer-employee relationship did not by themselves create Indian taxability for foreign employment income. The salary linked to work performed in India was not in issue on the same basis. The addition was deleted and that deletion was upheld. Case-Laws Income Tax Mon, 04 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761879