Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The ITAT ruled that the salary received by the assessee for an international assignment to the UK, being a resident of the UK and a non-resident of India, is not taxable in India. The Tribunal observed that the assessee had paid taxes in the UK on the salary income, and therefore, the foreign assignment salary earned by the assessee should be excluded while recomputing the income, as per Article 16(1) of the India-UK Tax Treaty.
The ITAT ruled that the salary received by the assessee for an international assignment to the UK, being a resident of the UK and a non-resident of India, is not taxable in India. The Tribunal observed that the assessee had paid taxes in the UK on the salary income, and therefore, the foreign assignment salary earned by the assessee should be excluded while recomputing the income, as per Article 16(1) of the India-UK Tax Treaty.
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