No tax leviable in India for salary income for services rendered in China

Sivakarthick Raman Vs ACIT (ITAT Chennai) ITAT Chennai held that salary income for services rendered in China is not taxable in India. Accordingly, benefit of exemption under Article 15(1) of the DTAA between India-China. Thus, order set aside and appeal allowed. Facts- The assessee, an employee of BMW India Private Limited (BMW India) was on an assignment/secondment to BMW Brilliance Automotive Limited (BMW China) during the FY 2021-22 and was rendering services/exercising employment with BMW China in China during this period. While on an International assignment with BMW China, the assessee ...