India-Korea DTAA Article 15(1): Korean Resident’s Salary for Services Outside India Not Taxable  

Amit Laroya Vs ACIT (ITAT Delhi) The recent decision by the Income Tax Appellate Tribunal (ITAT) in the case of Amit Laroya vs ACIT (ITAT Delhi) has significant implications for the taxation of salary income earned by a Korean resident for services rendered outside India. The key contention revolves around the applicability of Article 15(1) of the India-Korea Double Taxation Avoidance Agreement (DTAA). Amit Laroya, the appellant, contested the order of the Commissioner of Income Tax (CIT) in appeal dated 29/04/2022 against the order passed by the Dispute Resolution Panel (DRP) under Section 14...