PRAKASH RAMAN ,VADODARA vs. INCOME-TAX OFFICER, INTERNATIONAL TAXATION WARD 2 (1), CHENNAI

ITA 1115/CHNY/2025Status: DisposedITAT Chennai22 September 2025AY 2019-20Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI JAGADISH (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the issue is covered by previous decisions. While the assessee provided a Tax Residency Certificate (TRC) from the US as additional evidence, the Assessing Officer needs to verify its genuineness.

What were the facts?

The assessee, a non-resident, earned salary income from services rendered in the USA. The Assessing Officer taxed this income in India as it was paid by an Indian employer and received in India. The CIT(A) upheld this.

What were the issues?

Whether salary earned outside India for services rendered outside India by a non-resident is taxable in India, and whether benefits under the India-USA DTAA can be claimed without a timely filed TRC.

Which sections of the Income-tax Act were involved?

Section 5,Section 9,Section 15,Section 90,Section 234B

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Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI

Before: HON’BLE SHRI MANU KUMAR GIRI & HON’BLE SHRI JAGADISH

Hearing: 20.08.2025Pronounced: 22.09.2025

MANU KUMAR GIRI (Judicial Member)

This appeal is filed by the assessee against the order of the commissioner of Income Tax (Appeal) [‘CIT(A)’ in short], Chennai-16 dated 10.10.2024 for AY-2019-20. 2. The assessee has raised the following grounds of appeal:

1.

Re.: Taxability of salary income earned outside Ind

The order continues below.

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