Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
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Non-resident individual seconded on overseas assignment to UK - Salary received for employment exercised in UK taxable only in UK under Article 15(1) of India-UK DTAA, not taxable in India. Proportionate salary for services rendered in India offered to tax in India, balance salary offered to tax in UK, no foreign tax credit claimed. Identical issue decided in favor of assessee in Nanthakumar Murugesan case. Appellate Tribunal upheld deleting the addition made by lower authorities, deciding in favor of assessee on taxability of salary earned during overseas assignment.
Non-resident individual seconded on overseas assignment to UK - Salary received for employment exercised in UK taxable only in UK under Article 15(1) of India-UK DTAA, not taxable in India. Proportionate salary for services rendered in India offered to tax in India, balance salary offered to tax in UK, no foreign tax credit claimed. Identical issue decided in favor of assessee in Nanthakumar Murugesan case. Appellate Tribunal upheld deleting the addition made by lower authorities, deciding in favor of assessee on taxability of salary earned during overseas assignment.
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