Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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