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1. Denying the benefit u/s 91 - Tax Credit - Income accrue in India - assessee being “Resident but not Ordinarily Resident" is not a “Resident in India” - persons who are...

2. Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

3. Accrual of income in India - period of stay in India - salary received by the assessee from his foreign employer - DTAA between India and USA - Revenue contended that,...

4. Income accrued in India - Status of Non Resident - Determinative test for the status of Non Resident being number of days of stay in India and in assessee's case in...

5. Levy of tax on interest income - Status of the assessee - Resident but not ordinarily resident - NRI Account - Provisions of Section 5(2) are also not applicable as the...

6. Income accrued in India - Period of stay in India - This claim of the assessee has not been rebutted or denied by any of the lower authorities. Both the lower...

7. Income taxable in India - salary derived from Tanzania - resident but not ordinarily resident in India - eligibility of Relief u/s 90 - the salary is earned outside...

8. Taxability of salary income in India while rendering service in abroad - assessee is NRI - income accrued inside or outside India - assessee is a non-resident employee...

9. Foreign tax credit u/s 91 - Section 6(6) carves out another category of person in ‘Residents’, who is said to be ‘not ordinarily resident’ in India form part of larger...

10. Duty of AO to Guide the Assessee - Considering the specific facts on record that the assessee is non resident the amount which the ld. AO has taxed is earned and sourced...

11. Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the...

12. Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

13. Income accrued in India - Shipping income earned in India - India Singapore DTAA - income is exempt in the singapore - AO has made an attempt to deny the benefit of...

14. The commission has been paid to non-resident outside India for services rendered outside India - where the non-resident agent operates outside India, no part of his...

15. Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection -...