Depreciation and routine compliance expenses disallowance did not prove inaccurate particulars or misreporting; penalty sustained only on foreign trav...
The assessee, a US LLC engaged in providing domain name registration, web hosting, web designing, SSL certification services, etc., was held to be a tax resident of the USA and entitled to the benefits of the India-USA DTAA. The Tribunal recognized the assessee LLC, having two partners who are US residents filing a US partnership return, as a resident of the USA for taxation purposes. Regarding the taxability of income from services provided, the Tribunal remanded the issue to the AO to examine the applicability of the DTAA provisions vis-`a-vis the various services rendered by the assessee and the income received thereon, after providing an adequate opportunity of being heard.
The assessee, a US LLC engaged in providing domain name registration, web hosting, web designing, SSL certification services, etc., was held to be a tax resident of the USA and entitled to the benefits of the India-USA DTAA. The Tribunal recognized the assessee LLC, having two partners who are US residents filing a US partnership return, as a resident of the USA for taxation purposes. Regarding the taxability of income from services provided, the Tribunal remanded the issue to the AO to examine the applicability of the DTAA provisions vis-`a-vis the various services rendered by the assessee and the income received thereon, after providing an adequate opportunity of being heard.
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