Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The ITAT considered the taxability of salary earned in China by an individual residing in China. The AO argued that the salary was taxable in India due to an existing employer-employee relationship. However, the ITAT agreed with the argument that as the individual was a tax resident of China, the salary income was taxable in China only. The ITAT held that the salary for services in China was exempt u/s Article 15(1) of the India-China DTAA. The ITAT directed the AO to allow the exemption, noting that the proportionate salary for services in India had already been taxed in India and the remaining salary in China. The individual had not claimed foreign tax credit. Decision favored the assessee.
The ITAT considered the taxability of salary earned in China by an individual residing in China. The AO argued that the salary was taxable in India due to an existing employer-employee relationship. However, the ITAT agreed with the argument that as the individual was a tax resident of China, the salary income was taxable in China only. The ITAT held that the salary for services in China was exempt u/s Article 15(1) of the India-China DTAA. The ITAT directed the AO to allow the exemption, noting that the proportionate salary for services in India had already been taxed in India and the remaining salary in China. The individual had not claimed foreign tax credit. Decision favored the assessee.
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