Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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 4803
Join Channel
TaxTMI 
