Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Taxability of salary income earned by non-residents from Indian companies. In this Judgement, it was determined that under Section 9(1)(ii) of the Income Tax Act, salary income is taxable in India if earned in India. However, it was clarified that if the services are rendered outside India, the salary income cannot be taxed in India. - The Tribunal analyzed the definition of salary under Section 15 of the Income Tax Act, which includes salary due from an employer or paid/allowed to the employee. Considering the scope of total income under Section 5, the ITAT concluded that no taxability arises on salary/allowances received by the assessee as they were earned outside India.
Taxability of salary income earned by non-residents from Indian companies. In this Judgement, it was determined that under Section 9(1)(ii) of the Income Tax Act, salary income is taxable in India if earned in India. However, it was clarified that if the services are rendered outside India, the salary income cannot be taxed in India. - The Tribunal analyzed the definition of salary under Section 15 of the Income Tax Act, which includes salary due from an employer or paid/allowed to the employee. Considering the scope of total income under Section 5, the ITAT concluded that no taxability arises on salary/allowances received by the assessee as they were earned outside India.
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