Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
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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