Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
The assessee's income earned in the USA is taxable in India. The tie-breaker test under Article 4 of the India-US DTAA is not applicable, as the assessee's centre of vital interest remained in India. While the income is includable in the total income u/s 5 of the Income Tax Act, the Appellate Tribunal directed the Assessing Officer to grant credit for taxes paid abroad by the assessee on the same income to avoid double taxation.
The assessee's income earned in the USA is taxable in India. The tie-breaker test under Article 4 of the India-US DTAA is not applicable, as the assessee's centre of vital interest remained in India. While the income is includable in the total income u/s 5 of the Income Tax Act, the Appellate Tribunal directed the Assessing Officer to grant credit for taxes paid abroad by the assessee on the same income to avoid double taxation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
