Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
For treaty purposes, a taxpayer who was resident in both States under domestic law was treated as resident of Kazakhstan under the Article 4 tie-breaker, because he had no permanent home in India, was based in Kazakhstan, and his personal and economic relations were closer there. Salary earned for employment exercised in Kazakhstan was therefore taxable only in Kazakhstan, and the India addition was deleted. Rental income from a London property was governed by the India-United Kingdom DTAA and, under Article 6, was taxable only in the State where the property was situated, so that addition was also deleted. Dividend income from Netherlands shares was remanded for de novo adjudication under the India-Netherlands DTAA, with foreign tax credit to be considered if taxed in India. Interest income was directed to be taxed at the 10% treaty rate under the India-Kazakhstan DTAA.
For treaty purposes, a taxpayer who was resident in both States under domestic law was treated as resident of Kazakhstan under the Article 4 tie-breaker, because he had no permanent home in India, was based in Kazakhstan, and his personal and economic relations were closer there. Salary earned for employment exercised in Kazakhstan was therefore taxable only in Kazakhstan, and the India addition was deleted. Rental income from a London property was governed by the India-United Kingdom DTAA and, under Article 6, was taxable only in the State where the property was situated, so that addition was also deleted. Dividend income from Netherlands shares was remanded for de novo adjudication under the India-Netherlands DTAA, with foreign tax credit to be considered if taxed in India. Interest income was directed to be taxed at the 10% treaty rate under the India-Kazakhstan DTAA.
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