Stamp valuation increases after registration-fee payment led to deletion of property-purchase addition within tolerance and without valuation referral...
Capital Asset Conversion Requires Proven Business Stock Treatment; Paper Consideration in Spousal Flat Transfers Does Not Create Taxable Business Inco...
Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuin...
Commercial property status protects capital-gains exemption when residential-house ownership limits are tested, while agricultural-land character gove...
Accrual of income in India - period of stay in India - salary received by the assessee from his foreign employer - DTAA between India and USA - Revenue contended that, since the assessee was a resident and ordinarily resident in India during the year, therefore, the provisions of DTAA would not apply in the case of the assessee - the Tribunal found that the provisions of Article 16(2) of the DTAA are to be read together, and all conditions must be satisfied simultaneously to determine the tax liability of the assessee's foreign income. It held that the income earned by the assessee in the USA should be taxed in the USA, as the conditions under Clause (a), (b), and (c) of Article 16(2) were not fully met.
Accrual of income in India - period of stay in India - salary received by the assessee from his foreign employer - DTAA between India and USA - Revenue contended that, since the assessee was a resident and ordinarily resident in India during the year, therefore, the provisions of DTAA would not apply in the case of the assessee - the Tribunal found that the provisions of Article 16(2) of the DTAA are to be read together, and all conditions must be satisfied simultaneously to determine the tax liability of the assessee's foreign income. It held that the income earned by the assessee in the USA should be taxed in the USA, as the conditions under Clause (a), (b), and (c) of Article 16(2) were not fully met.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
