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Facts
The assessee, a non-resident, appealed against the decision of the lower authorities holding his salary of Rs. 6,25,494/- earned in Muscat as taxable in India. The proceedings originated under section 143(1) of the Income-tax Act, 1961.
Held
The Tribunal, relying on the precedent of Utanka Roy vs. DIT, held that the salary income earned by the assessee for services rendered abroad (in Muscat) is not taxable in India.
Key Issues
Whether salary income earned by a non-resident for services rendered outside India is taxable in India.
Sections Cited
143(1)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
ORDER This assesseee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals), Addl./JCIT(A)- 3, Chennai [in short, the “CIT(A)”], DIN and order No. ITBA/APL/S/250/2025-26/1084191711(1), dated 30.12.2025 involving proceedings under section 143(1) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.
It next emerges with the able assistance coming from both the parties that the assessee/appellant is aggrieved against the