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2012 (5) TMI 42 - HC - Income TaxProfit in lieu of salary for services rendered outside India - ITAT deleted the addition made by the AO – Held that:- Payment in question was received towards retirement benefit/severance/vacation engagement from the erstwhile employer on termination of employment in November, 1999 - employer was based in USA and services were rendered to the erstwhile employer in USA - the said amount cannot be taxed in India as the status of the assessee during the year in question was that of “not ordinary resident” - said income did not accrue or arise in India in terms of Section 6 and Section 9(1) (ii) - in favour of the assessee.
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