Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Income taxable in India or not - Salary income - Australia assignment period - incomes deemed to accrue or arise in India as assessee is a non-resident - Despite non-submission of TRC, the Assessee provided alternate evidence supporting his tax residency in Australia. The Tribunal considered this evidence, along with the submissions made during assessment proceedings and objections raised before the DRP. Ultimately, the Tribunal ruled in favor of the Assessee, allowing the exemption claim on the grounds of his residency status and the nature of employment exercised in Australia.
Income taxable in India or not - Salary income - Australia assignment period - incomes deemed to accrue or arise in India as assessee is a non-resident - Despite non-submission of TRC, the Assessee provided alternate evidence supporting his tax residency in Australia. The Tribunal considered this evidence, along with the submissions made during assessment proceedings and objections raised before the DRP. Ultimately, the Tribunal ruled in favor of the Assessee, allowing the exemption claim on the grounds of his residency status and the nature of employment exercised in Australia.
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