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...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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