Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
ITAT allowed the assessee's additional claim, holding that while the AO may lack jurisdiction to adjudicate an additional claim absent a revised return, the appellate authority possesses jurisdiction to admit such a claim. The Tribunal found prima facie merit in the assessee's contention that she is a not-ordinarily-resident and not a resident, and that certain foreign income should therefore not be taxable in India. The appeal was remitted to the AO for a limited purpose: to verify the assessee's period of stay from 01.04.2005 to 31.03.2012 under section 6(6) of the Income-tax Act, determine residential status, and grant any reliefs as per law. Grounds 1 and 2 were allowed for statistical purposes.
ITAT allowed the assessee's additional claim, holding that while the AO may lack jurisdiction to adjudicate an additional claim absent a revised return, the appellate authority possesses jurisdiction to admit such a claim. The Tribunal found prima facie merit in the assessee's contention that she is a not-ordinarily-resident and not a resident, and that certain foreign income should therefore not be taxable in India. The appeal was remitted to the AO for a limited purpose: to verify the assessee's period of stay from 01.04.2005 to 31.03.2012 under section 6(6) of the Income-tax Act, determine residential status, and grant any reliefs as per law. Grounds 1 and 2 were allowed for statistical purposes.
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