Allowing the appeal the Tribunal held that the assessee being a non-resident in India and was liable to tax in Austria for services rendered in Austria in pursuance of article 15 of DTAA between India and Austria, Assessing Officer was not justified in taxing said salary income on ground that assessee could not produce Tax Residency Certificate from said country. (AY. 2014-15)
Vamsee Krishna Kundurthi v. ITO (2021) 190 ITD 68 (Hyd.)(Trib.)
S. 90 : Double taxation relief-Salary-Tax Residency certificate-Salary income from Australia cannot be taxed in India-DTAA-India-Australia. [S. 5(2), 9(1)(1), 10, Art. 15]