2025 (10) TMI 1394

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....nue : Shri Ganesh R Ghale, Standing Counsel for Department ORDER PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the order passed by the NFAC, Delhi vide order dated 09/06/2023 in DIN No. ITBA/NFAC/S/250/2023-24/1053642679(1) for the assessment year 2017-18. 2. The only issue raised by the assessee is that the salary income of Rs.19,78,810 rece....

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....assessee failed to furnish the required documents as detailed below: "a) Terms of assignment with documentary evidence. b) Copy of the contract between employer and assessee. c) Copy of the return filed in UK and proof of taxes paid on those incomes. d) Working on total number of days residing in India." 6. In the absence of such evidence, the AO added the in....

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....perused the material on record. The facts show that the assessee was on assignment in the UK during the year under consideration. She claims that she was a non-resident and her salary is not taxable in India under Article 16(1) of the India-UK DTAA. However, the AO made the addition due to lack of supporting documents. 10.1 We note that the provisions of Article 16(1) of the India-UK DTAA deal ....