Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
The principal issue was residential status under s.6(1) Explanation 1(b) for AYs 2017-18 to 2019-20. Applying the exclusion of day of arrival (per Manoj Kumar Reddy) the assessee's stays were under 182 days (180, 173, 175), so he did not meet the 182-day threshold; accordingly he is not a resident for those years - outcome: non-resident. Separately, under Explanation (e) to s.115C the assessee was outside India for employment, reinforcing non-resident status. The tribunal allowed the taxpayer's grounds and held him non-resident for the three assessment years. - ITAT
The principal issue was residential status under s.6(1) Explanation 1(b) for AYs 2017-18 to 2019-20. Applying the exclusion of day of arrival (per Manoj Kumar Reddy) the assessee's stays were under 182 days (180, 173, 175), so he did not meet the 182-day threshold; accordingly he is not a resident for those years - outcome: non-resident. Separately, under Explanation (e) to s.115C the assessee was outside India for employment, reinforcing non-resident status. The tribunal allowed the taxpayer's grounds and held him non-resident for the three assessment years. - ITAT
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