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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT examined residential status dispute of NRI taxpayer under Income Tax Act section 6(1) and applicable DTAA provisions. Appellant demonstrated presence in India for 132 days during relevant assessment year, below the 182-day threshold required for resident status. Supporting documentation included foreign employment records and visit passes. ITAT remanded matter to Assessing Officer for detailed verification of appellant's Singapore residential status and Indian non-residential position, specifically directing examination under Explanation 1 to section 6(1)(c). Appeal grounds 1-3 were allowed for statistical purposes pending final determination of residential status by AO based on documentary evidence.
ITAT examined residential status dispute of NRI taxpayer under Income Tax Act section 6(1) and applicable DTAA provisions. Appellant demonstrated presence in India for 132 days during relevant assessment year, below the 182-day threshold required for resident status. Supporting documentation included foreign employment records and visit passes. ITAT remanded matter to Assessing Officer for detailed verification of appellant's Singapore residential status and Indian non-residential position, specifically directing examination under Explanation 1 to section 6(1)(c). Appeal grounds 1-3 were allowed for statistical purposes pending final determination of residential status by AO based on documentary evidence.
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