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    <title>2024 (7) TMI 841 - ITAT AHMEDABAD</title>
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    <description>A non-resident&#039;s salary for services performed on a foreign ship in the Exclusive Economic Zone was held not taxable in India because the work was outside territorial waters and was not shown to fall within offshore activities specifically covered by the applicable notification. The note also records that a valid scrutiny notice under section 143(2) did not need to be reissued merely because the Assessing Officer changed, and that the assessment was not barred by limitation where the draft assessment order was issued within time and the section 144C procedure was followed. The procedural objections therefore failed, while the offshore salary addition was deleted.</description>
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    <pubDate>Fri, 12 Jul 2024 00:00:00 +0530</pubDate>
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      <title>2024 (7) TMI 841 - ITAT AHMEDABAD</title>
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      <description>A non-resident&#039;s salary for services performed on a foreign ship in the Exclusive Economic Zone was held not taxable in India because the work was outside territorial waters and was not shown to fall within offshore activities specifically covered by the applicable notification. The note also records that a valid scrutiny notice under section 143(2) did not need to be reissued merely because the Assessing Officer changed, and that the assessment was not barred by limitation where the draft assessment order was issued within time and the section 144C procedure was followed. The procedural objections therefore failed, while the offshore salary addition was deleted.</description>
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