Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
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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