12 May 2011
In case of a non resident individual who has been employed on secondment by the Indian Company any remursment of amount towards contribution to social security fund i.e Contribution to pension fund , life insurance fund maintained outside india by the foreign employer is liable to be taxed ? if yes under what section .
13 May 2011
Here the stay of the Indian National outside India needs to be seen, if the same is for more than 182 days then the income earned outside India is not taxable.
14 May 2011
He was in india for more than 182 days. & hence his status was "resident but not ordinary". Now as per DTAA, salary earned in india is only taxable. so my query is that contribution made to social security fund maintained outside india can be deemed to be earned in India.
pls justify the replies with supporting section/ provision/ case law .
CAclubindia
