Held, that the assessee was non-resident in India and a resident of Singapore which was evidenced by the tax residency certificates furnished by the assessee. The income in question had already been offered to tax in Singapore and the assessee had paid taxes thereon. No credit for tax paid in India had been taken in Singapore. On these facts, the assessee would be entitled to the benefit of article of the Double Taxation Avoidance Agreement between India and Singapore which provides that the salary would be taxable in the country wherein the employment is exercised. The order of the Commissioner (Appeals) is affirmed  subject to verification by the Assessing Officer that this income has already been offered to tax in Singapore and the assessee had paid due taxes thereon and that no credit of taxes paid in India had been taken by the assessee in Singapore.(AY.2019-20)