Case Law Analysis
|Income Tax Appellate Tribunal
DTAA Article 15 | Foreign Salary Taxable Only in Country of Service Rendering : ITAT Delhi Overrules Domestic Taxation
ITAT Delhi clarifies that under Article 15 of the India-Australia DTAA, salary for services rendered abroad is taxable exclusively in the country where the services are performed, not in India. The ruling shields foreign-earned income of Indian residents from double taxation, reinforcing DTAA supremacy over domestic tax laws.