Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
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Treaty exemption for foreign salary requires verification of the taxpayer's Tax Residency Certificate, Korean tax return, tax-payment evidence and other supporting documents before relief under Article 15(1) of the India-Korea DTAA can be allowed. Salary earned by a non-resident for services performed outside India is not ordinarily income earned in India merely because an Indian employer paid it or deducted tax. The exemption claim was restored for limited verification and fresh adjudication. Delay in filing the first appeal was condoned because medical emergency and difficulty accessing the e-filing portal did not indicate gross negligence or deliberate inaction.
Treaty exemption for foreign salary requires verification of the taxpayer's Tax Residency Certificate, Korean tax return, tax-payment evidence and other supporting documents before relief under Article 15(1) of the India-Korea DTAA can be allowed. Salary earned by a non-resident for services performed outside India is not ordinarily income earned in India merely because an Indian employer paid it or deducted tax. The exemption claim was restored for limited verification and fresh adjudication. Delay in filing the first appeal was condoned because medical emergency and difficulty accessing the e-filing portal did not indicate gross negligence or deliberate inaction.
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