2023 (9) TMI 1680

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....is appeal relates to taxability in India of an amount of Rs. 55,60,693/- received as salary income. 3. Briefly, the facts are, the assessee is a non-resident individual. For the assessment year under dispute, the assessee filed her return of income on 24.12.2022 declaring income of Rs. 9,83,425/-. As stated by the Assessing Officer, in the assessment year under consideration, the assessee has received salary income from M/s. Corning Technologies India Private Limited. In course of assessment proceedings, while verifying the return of income filed by the assessee, the Assessing Officer observed that the assessee claimed herself to be a tax resident of USA and claimed that the salary income of Rs. 55,60,693/- was not received in course of ....

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....enefit in the light of the TRC. 6. Without prejudice, she submitted that the salary income in dispute has no connection with any services rendered in India, but was received for services rendered outside India. She submitted, the assessee, being tax resident of USA, the salary income has to be taxed in USA and not in India. 7. Learned Departmental Representative submitted, since the TRC was not furnished before the departmental authorities and now the assessee wants to furnish the TRC, the matter can be restored back to the Assessing Officer for examining assessee's claim. 8. We have considered rival submissions and perused material on record. The short issue arising for consideration is whether salary income of Rs. 55,60,693/- rec....