Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
