Remuneration to Danish nationals not taxable in India if it is not borne by a PE of NR in India

IT/ILT : Where Danish nationals were remunerated in respect of employment in India for a period not exceeding 183 days in concerned fiscal year and such remuneration was paid by or on behalf of an employer, who was not a resident of country and, in any event, remuneration was not borne by a permanent establishment or a fixed base, which employer had in India, said remuneration would be taxable in Denmark and not in India