https://www.taxtmi.com/caselaws?id=56119 Foreign technicians deputed to an Indian project were treated as continuing employees of the foreign enterprise, so their remuneration was regarded as income of the foreign employer rather than taxable income in India in their hands. The statutory exemption under section 10(6)(vi) was considered satisfied, section 10(6)(viia) was held inapplicable, and Article VII of the India-Japan double taxation agreement also supported exemption because the technicians stayed in India for less than the prescribed period and the remuneration was not deductible in computing Indian taxable profits. On that basis, the remuneration was not chargeable to Indian income-tax. en-us Sun, 18 Sep 1994 00:00:00 +0530 Wed, 01 Dec 2010 16:41:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=56119 Foreign technicians deputed to an Indian project were treated as continuing employees of the foreign enterprise, so their remuneration was regarded as income of the foreign employer rather than taxable income in India in their hands. The statutory exemption under section 10(6)(vi) was considered satisfied, section 10(6)(viia) was held inapplicable, and Article VII of the India-Japan double taxation agreement also supported exemption because the technicians stayed in India for less than the prescribed period and the remuneration was not deductible in computing Indian taxable profits. On that basis, the remuneration was not chargeable to Indian income-tax. Case-Laws Income Tax Sun, 18 Sep 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=56119