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    <title>2024 (7) TMI 841 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad upheld the assessment order dated 22/10/2021 as being within the statutory time limit under Section 144C(4). The tribunal ruled that successor AOs need not issue fresh notices under Section 143(2) when procedural compliance was initially met. However, the tribunal allowed the assessee&#039;s appeal regarding salary income taxation. The assessee, employed by a Singapore company for underwater inspection on foreign ships in India&#039;s EEZ, was deemed non-resident based on CDC verification. Since the work was performed on foreign ships beyond territorial waters and not covered by GSR 304(E) notification, the salary income was held exempt under the Income Tax Act.</description>
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      <description>The ITAT Ahmedabad upheld the assessment order dated 22/10/2021 as being within the statutory time limit under Section 144C(4). The tribunal ruled that successor AOs need not issue fresh notices under Section 143(2) when procedural compliance was initially met. However, the tribunal allowed the assessee&#039;s appeal regarding salary income taxation. The assessee, employed by a Singapore company for underwater inspection on foreign ships in India&#039;s EEZ, was deemed non-resident based on CDC verification. Since the work was performed on foreign ships beyond territorial waters and not covered by GSR 304(E) notification, the salary income was held exempt under the Income Tax Act.</description>
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