Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
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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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