Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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 
of 4798
Join Channel
TaxTMI 
