Non-Compete Payments Classified as Salary, Not Taxable in India Under DTAA Article 16, Affecting Tax Assessments.

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....Income accrued in India - Characterization of income - 'Salary' or 'Profit in lieu of Salary' OR 'Business income' - The amount paid to the employees under the non compete agreement is covered by the expression 'salary / profits in lieu of salary', which is not taxable in India in view of Article 16 of DTAA.....