Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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