Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Assessee filed revised return of income and Form 67 within extended due date. Assessee paid taxes on salary earned in Netherlands under Article 23 of India-Netherlands DTAA. Late filing of Form 67 cannot be reason for denying treaty benefit when salary earned abroad and tax paid in foreign country. Assessee cannot be taxed twice on same income resulting in double taxation. CIT(A) and AO erred in denying assessee's claim. Appeal allowed.
Assessee filed revised return of income and Form 67 within extended due date. Assessee paid taxes on salary earned in Netherlands under Article 23 of India-Netherlands DTAA. Late filing of Form 67 cannot be reason for denying treaty benefit when salary earned abroad and tax paid in foreign country. Assessee cannot be taxed twice on same income resulting in double taxation. CIT(A) and AO erred in denying assessee's claim. Appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
