SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Foreign salary earned by a non-resident and received in USD in an NRE account requires assessment of evidence establishing foreign employment, non-residential status, and receipt of salary. Passport entries, employment records, and NRE account details are material evidence and should be considered. The absence of foreign tax returns, a tax residency certificate, or proof of foreign tax payment does not alone warrant rejection of the claim where available records support it. Assessment should address these documents without treating foreign tax records as a mandatory condition.
Foreign salary earned by a non-resident and received in USD in an NRE account requires assessment of evidence establishing foreign employment, non-residential status, and receipt of salary. Passport entries, employment records, and NRE account details are material evidence and should be considered. The absence of foreign tax returns, a tax residency certificate, or proof of foreign tax payment does not alone warrant rejection of the claim where available records support it. Assessment should address these documents without treating foreign tax records as a mandatory condition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
