Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
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Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
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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