https://www.taxtmi.com/caselaws?id=795146 Place-of-effective-management residency rules did not apply for the relevant period to companies within the turnover or gross-receipts exclusion in Circular No. 08/2017, which bound the tax department. Once New Zealand residence and tax liability were determined, the income was not liable to Indian tax. Section 155(14A), read with Rule 128, was described as substantive as well as procedural relief for settled foreign-tax liability; procedural requirements could not defeat protection against double taxation. Indian tax not lawfully due was refundable, with interest in accordance with law, and rejection of the refund claim was treated as invalid. en-us Thu, 25 Jun 2026 00:00:00 +0530 Fri, 17 Jul 2026 08:37:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795146 Place-of-effective-management residency rules did not apply for the relevant period to companies within the turnover or gross-receipts exclusion in Circular No. 08/2017, which bound the tax department. Once New Zealand residence and tax liability were determined, the income was not liable to Indian tax. Section 155(14A), read with Rule 128, was described as substantive as well as procedural relief for settled foreign-tax liability; procedural requirements could not defeat protection against double taxation. Indian tax not lawfully due was refundable, with interest in accordance with law, and rejection of the refund claim was treated as invalid. Case-Laws Income Tax Thu, 25 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795146