ITAT remanded the case to CIT(A) for fresh adjudication...

ITAT remanded the case to CIT(A) for fresh adjudication regarding salary income taxability of an assessee serving as proprietor of an Indian entity and director of a Hong Kong-based company. The Tribunal found insufficient documentary evidence to determine whether salary income was earned outside India, as the assessee failed to provide certified copies of balance sheets, profit & loss accounts, appointment letters, ownership details, and ledger accounts of both Indian and Hong Kong entities. The Tribunal directed CIT(A) to consider the assessee's changed residential status during assessment proceedings and provide adequate hearing opportunity. Following precedent established in Babubhai Ramanbhai Patel case, the assessee must submit requisite documents to enable proper determination of income accrual location and residential status implications for tax liability assessment.

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