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...
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Income deemed to accrue or arise in India - residential status of the assessee under the India-USA DTAA. Assessee stayed in India for more than 183 days, considered a resident. Economic relationship, place of business, property administration, earning wages are important factors. Assessee has a private limited company in India involved in film distribution, attended board meetings, has operative bank accounts and mutual fund investments. In USA, assessee derives rental income, has bank accounts and investments, but no active involvement in earning wages or profits. Personal and economic relationships tilt more towards India. Assessee is a resident of India under Article 4(2)(a) of the Indo-US DTAA. All income derived in USA is chargeable to tax in India u/s 5 of the Income Tax Act. No tax credit available as no tax paid in USA. Dividend income, capital gains sourced in USA are taxable in India. Order of lower authorities confirmed, decided against assessee.
Income deemed to accrue or arise in India - residential status of the assessee under the India-USA DTAA. Assessee stayed in India for more than 183 days, considered a resident. Economic relationship, place of business, property administration, earning wages are important factors. Assessee has a private limited company in India involved in film distribution, attended board meetings, has operative bank accounts and mutual fund investments. In USA, assessee derives rental income, has bank accounts and investments, but no active involvement in earning wages or profits. Personal and economic relationships tilt more towards India. Assessee is a resident of India under Article 4(2)(a) of the Indo-US DTAA. All income derived in USA is chargeable to tax in India u/s 5 of the Income Tax Act. No tax credit available as no tax paid in USA. Dividend income, capital gains sourced in USA are taxable in India. Order of lower authorities confirmed, decided against assessee.
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