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    <title>2025 (1) TMI 901 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai ruled in favor of the assessee regarding salary earned for services rendered in Egypt but received in India. The CIT(A) had upheld the AO&#039;s addition under section 5(2), treating the salary as taxable income deemed to accrue in India. However, the ITAT held that salary received in India for services rendered outside India is not taxable under section 9(1)(ii) of the Act, relying on precedents from ITAT Delhi and Calcutta HC. The AO was directed to delete the addition.</description>
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      <description>The ITAT Mumbai ruled in favor of the assessee regarding salary earned for services rendered in Egypt but received in India. The CIT(A) had upheld the AO&#039;s addition under section 5(2), treating the salary as taxable income deemed to accrue in India. However, the ITAT held that salary received in India for services rendered outside India is not taxable under section 9(1)(ii) of the Act, relying on precedents from ITAT Delhi and Calcutta HC. The AO was directed to delete the addition.</description>
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