Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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Assessee employed by Indian entity but sent on long-term international assignment to Singapore. Salary received in India for administrative reasons, but employment exercised in Singapore. Assessee non-resident in India, resident of Singapore evidenced by Tax Residency certificates. Income offered to tax in Singapore, taxes paid thereon, no credit of Tax paid in India taken in Singapore. Assessee entitled to benefit of Article 15 of relevant DTAA, salary taxable in country where employment exercised. AO to verify income offered to tax in Singapore, taxes paid, no credit of Taxes paid in India taken by assessee in Singapore. As per Sec. 15(a), regular salary chargeable to tax. Sec. 9(1)(ii), salary income deemed to accrue or arise in India if earned in India for services rendered in India. Treaty benefit applicable to persons residents of both India and treaty partner country. Salary earned for work performed in treaty partner country taxable there.
Assessee employed by Indian entity but sent on long-term international assignment to Singapore. Salary received in India for administrative reasons, but employment exercised in Singapore. Assessee non-resident in India, resident of Singapore evidenced by Tax Residency certificates. Income offered to tax in Singapore, taxes paid thereon, no credit of Tax paid in India taken in Singapore. Assessee entitled to benefit of Article 15 of relevant DTAA, salary taxable in country where employment exercised. AO to verify income offered to tax in Singapore, taxes paid, no credit of Taxes paid in India taken by assessee in Singapore. As per Sec. 15(a), regular salary chargeable to tax. Sec. 9(1)(ii), salary income deemed to accrue or arise in India if earned in India for services rendered in India. Treaty benefit applicable to persons residents of both India and treaty partner country. Salary earned for work performed in treaty partner country taxable there.
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