TaxTMI 
TaxTMI 
2024 (10) TMI 1831
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....4/2024 for the Assessment Year 2020-21. 2. Following grounds of appeal have been raised by the appellant: "Not considering correct residential status of the Appellant 1. erred in denying consideration of correct residential status of the Appellant as Resident but not Ordinary Resident ('RNOR') and instead considering the residential status as Resident and Ordinary Resident (ROR") as inadvertently reported in the ITR: Income from House Property in Singapore: 2. erred in considering Rs.10,88,526 as an income from Singapore house property as taxable in India, without considering that the Appellant is RNOR, and such income is not taxable in India, Salary income from Singapore: 3. ....
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....peal, at any time before or at the time of the appeal." 3. The facts of the case, in brief, are that the assessee is an individual and has filed the return of income electronically for the assessment year 2020 21 on 27/02/2021 considering his residential status as a Resident and Ordinarily Resident (ROR) of India u/s. 6(1) of the Act and has declared following income: 1. Income from salary - Rs. 3,44,15,444/- 2. Income(loss) from house property - Rs. (2,00,000/-) 3. Income from other sources - Rs. 4,10,084/- The appellant has declared a net income of Rs.3,44,40,530/- after claiming deduction of Rs.1,85,000/- under Chapter VI-A of the Act. 4. However, the appellant had erroneously filed the above return of....
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....uring the said assessment years, the appellant was an employee of AAK Singapore Pvt. Ltd. until 31/12/2019 and thereafter, he took a local independent employee contract with AAK Kamani Pvt. Ltd., (hereinafter referred to as 'AAK IND'). The appellant had received a gross salary of Rs.1,28,36,633/- from AAK India which has been duly reported in the form 16 issued by AAK India. In addition to above, as regards the Singapore employment, the appellant received a gross salary of SGD 5,39,600/- (for the period from 1st January 2019 and 31st December, 2019) and correspondingly a tax of SGD 95,679,54/- was paid by the appellant to the Singapore tax authorities for the said calendar year. However, during the period from 01/04/2019 to 31/12/2019 (peri....
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....on u/s. 154 of the Act with the CPC. Accordingly, the same was submitted online vide rectification reference no.226825810170222 dated 17/02/2022. The said rectification request was rejected by the CPC and the order u/s. 154 of the Act was issued to the appellant on 02/06/2022. While the claim of foreign tax credit as per section 90 of the Act was not disallowed, additionally, the loss under the head 'house property' of Rs.11,33,502/- (as claimed in the original return) was also disallowed by the CPC. Moreover, no reason was provided by the CPC for disallowing the aforesaid claim in the rectification order. Additionally, in view of the above disallowances, CPC has also issued a demand notice u/s. 156 of the Act for payment of demand of Rs....