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    <title>2024 (11) TMI 1316 - ITAT KOLKATA</title>
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    <description>A non-resident employee&#039;s salary and foreign assignment allowances for services rendered in Indonesia were treated as not taxable in India because the income neither accrued nor arose in India and was not received there. The fact that the employer was an Indian company did not by itself make the foreign earnings taxable. Non-production of the tax residency certificate was treated as a procedural lapse, not a basis to deny treaty relief where the surrounding facts supported non-taxability. The addition was deleted.</description>
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