Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Treaty residency under the India-US DTAA turned on the tie-break test, especially the assessee's centre of vital interests. The Tribunal noted that personal ties could point to the US because the immediate family resided there, but economic ties appeared substantially rooted in India. Because critical facts on family residence, US-return income breakup, and prior-year treatment were not adequately established, the matter could not be decided on the existing record. Applying the approach in Ashok Kumar Pandey, the Tribunal required examination of the nucleus family and active commercial involvement, and remanded the case for fresh factual verification and adjudication after giving the assessee an opportunity to be heard.
Treaty residency under the India-US DTAA turned on the tie-break test, especially the assessee's centre of vital interests. The Tribunal noted that personal ties could point to the US because the immediate family resided there, but economic ties appeared substantially rooted in India. Because critical facts on family residence, US-return income breakup, and prior-year treatment were not adequately established, the matter could not be decided on the existing record. Applying the approach in Ashok Kumar Pandey, the Tribunal required examination of the nucleus family and active commercial involvement, and remanded the case for fresh factual verification and adjudication after giving the assessee an opportunity to be heard.
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