Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Page of 4883
Press 'Enter' after typing page number.
321 to 340 of 97649 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The appellant qualified as a non-resident in India during the previous year 2015-16. A non-resident is taxable in India only for income received/deemed to be received or accrued/deemed to accrue in India. The foreign allowances received by the appellant in the United Kingdom for services rendered there do not fall within the scope of total income u/s 5(2) of the Act. The value of stock option prerequisites accrued to the appellant for services rendered outside India from the date of grant to vesting does not form part of the total income of a non-resident and is not taxable in India. Section 90(2) of the Act applies, and the appellant is eligible for exemption under Article 16(1) of the India-UK DTAA, having filed a tax residency certificate qualifying as a UK tax resident. The disallowance of deductions under Chapter VI-A and long-term capital gain exemption u/s 10(38) were allowed by the CIT(A) subject to verification.
The appellant qualified as a non-resident in India during the previous year 2015-16. A non-resident is taxable in India only for income received/deemed to be received or accrued/deemed to accrue in India. The foreign allowances received by the appellant in the United Kingdom for services rendered there do not fall within the scope of total income u/s 5(2) of the Act. The value of stock option prerequisites accrued to the appellant for services rendered outside India from the date of grant to vesting does not form part of the total income of a non-resident and is not taxable in India. Section 90(2) of the Act applies, and the appellant is eligible for exemption under Article 16(1) of the India-UK DTAA, having filed a tax residency certificate qualifying as a UK tax resident. The disallowance of deductions under Chapter VI-A and long-term capital gain exemption u/s 10(38) were allowed by the CIT(A) subject to verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
