Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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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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