Held that since assessee qualified as a non-resident in India and salary and allowances were earned by assessee in respect of employment rendered in Belgium due to his foreign assignment, as per article 15, Assessing Officer was directed to allow exemption. (AY. 2014-15)
Ranjit Kumar Vuppu v. ITO(IT) (2021) 190 ITD 455 (Hyd.)(Trib.)
S. 9(1)(ii) : Income deemed to accrue or arise in India-Salaries-Dependent personal services-Non-Resident-Salary and allowance outside India-Failure to produce tax residency certificate-Not taxable in India-DTAA-India-Belgium. [S. 5(2), 15, 90(4), Art. 15(1)]