Only Top-level Managerial Persons Exempt from Tax under DTAA with Poland

Assessee is employed with Zaklady Farmaceutyczne Polpharma SA’s at its office at Bangalore from 14.6.2004. From 1.6.2005, the Assessee was appointed as Business Development Director at Bangalore in India. The Assessee received gross salary of US $ 24,093 (equivalent to Rs 10,86,950/-) in AY 2005-06 and US $ 18,836 (equivalent to Rs 8,15,795) in AY 2006-07. The Assessee has furnished certificate dated 25th August 2005 issued by Polpharma and which is placed at page 98 of the paper book which certifies that the Assessee has been appointed by the company as ‘Service Provider’ whose category...