Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Foreign salary earned by a non-resident and received in USD in an NRE account requires assessment of evidence establishing foreign employment, non-residential status, and receipt of salary. Passport entries, employment records, and NRE account details are material evidence and should be considered. The absence of foreign tax returns, a tax residency certificate, or proof of foreign tax payment does not alone warrant rejection of the claim where available records support it. Assessment should address these documents without treating foreign tax records as a mandatory condition.
Foreign salary earned by a non-resident and received in USD in an NRE account requires assessment of evidence establishing foreign employment, non-residential status, and receipt of salary. Passport entries, employment records, and NRE account details are material evidence and should be considered. The absence of foreign tax returns, a tax residency certificate, or proof of foreign tax payment does not alone warrant rejection of the claim where available records support it. Assessment should address these documents without treating foreign tax records as a mandatory condition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
