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    <title>2026 (6) TMI 95 - ITAT DELHI</title>
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    <description>A non-resident employee&#039;s per diem linked to a UK assignment was treated as not taxable in India under Article 16(1) of the India-UK DTAA read with section 90, because remuneration for employment exercised in the other contracting state may be taxed in that state. The assessee had filed the assignment agreement, passport travel records and a UK tax residency certificate, supporting the claim of non-resident status and treaty relief. The balance salary was already offered to tax in India, and the revenue&#039;s inference that the full amount had not been properly returned was not accepted. The addition made on the per diem amount was deleted.</description>
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