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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...
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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