Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
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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