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Non-compete fees paid to employees rendering services in USA was profit in lieu of salary; not taxable in India

June 26, 2020[2020] 117 278 (Karnataka)/[2020] 428 ITR 194 (Karnataka)

INTERNATIONAL TAXATION : Non-compete fee paid to two employees who had accepted assessee's employment and rendered services in USA,was to be regarded as salary/profit in lieu of salary under article 16 of India- USA, DTAA, and, thus, same was not liable to tax in India

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