Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Rectification u/s 154 - taxation of salary income earned in USA - The appeal before the Appellate Tribunal involved various issues related to the taxation of income earned by the appellant for the assessment year 2014-15. The Tribunal upheld the validity of the order issued under Section 154, rectifying factual mistakes in the assessment order. It affirmed the appellant's tax residency status as being in India, thereby subjecting the income earned in the USA to taxation in India. The Tribunal emphasized the need for offering global income for taxation and directed the Assessing Officer to consider the appellant's eligibility for relief under the India-USA treaty provisions.
Rectification u/s 154 - taxation of salary income earned in USA - The appeal before the Appellate Tribunal involved various issues related to the taxation of income earned by the appellant for the assessment year 2014-15. The Tribunal upheld the validity of the order issued under Section 154, rectifying factual mistakes in the assessment order. It affirmed the appellant's tax residency status as being in India, thereby subjecting the income earned in the USA to taxation in India. The Tribunal emphasized the need for offering global income for taxation and directed the Assessing Officer to consider the appellant's eligibility for relief under the India-USA treaty provisions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
