Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
