Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Per-diem received by a non-resident employee for services performed in the United Kingdom was not chargeable to tax in India where the employment was exercised abroad, the stay in India was below the prescribed period, and a UK tax residency certificate was produced. The Tribunal applied Article 16(1) of the India-UK DTAA, read with section 90, and held that remuneration arising from the UK assignment was taxable, if at all, in the United Kingdom and not in India. The addition made by treating the per-diem and related salary adjustment as Indian taxable income was therefore deleted.
Per-diem received by a non-resident employee for services performed in the United Kingdom was not chargeable to tax in India where the employment was exercised abroad, the stay in India was below the prescribed period, and a UK tax residency certificate was produced. The Tribunal applied Article 16(1) of the India-UK DTAA, read with section 90, and held that remuneration arising from the UK assignment was taxable, if at all, in the United Kingdom and not in India. The addition made by treating the per-diem and related salary adjustment as Indian taxable income was therefore deleted.
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