Taxability of Salary paid to Non Resident director for services rendered outside india

Salary paid to NR director for services rendered to US based branch of Co. wasn't taxable in India

IN THE ITAT MUMBAI BENCH 'I'

Deputy Commissioner of Income-tax-2(3) Mumbai

v.

Swift Freight India Ltd

R.C. SHARMA, ACCOUNTANT MEMBER
AND VIJAY PAL RAO, JUDICIAL MEMBER

IT APPEAL NO. 5598 (MUM.) OF 2009
[ASSESSMENT YEAR 2006-07]

JANUARY  14, 2015 

Section 9, read with section 40(a)(i), of the Income-tax Act, 1961 - Income-Deemed to Accure or Arise in India (Salary) - Assessment year 2006-07 - Whether where MD was a non resident and salary was received by him outside India for services rendered outside India, no TDS need to be deducted and disallowance under section 40(a)(i) for salary payment - Held, yes [Para 4.5] [In favour of assessee]