Held that  salary income as accrued to the assessee for work performed in a foreign jurisdiction would not be taxable in India whereas salary received for work performed in India would be taxable in India. The benefit of the Double Taxation Avoidance Agreement would be available to the assessee. The proportionate salary for services rendered in India had already been offered to tax in India whereas the balance salary had been offered to tax in China. The salary reconciliation statement has been placed on record. The assessee had not claimed any foreign tax credit in any of the jurisdiction. The China tax had been paid by the foreign entity, F and the assessee had offered salary income on gross basis. Salary income could be deemed to accrue or arise in India only if it is earned in India in respect of services rendered in India. The Assessing Officer is directed to   recompute the income of the assessee.(AY.2015-16)