Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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.
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