9911796707
TMI Blog2024 (2) TMI 606X X X X Extracts X X X X X X X X Extracts X X X X ..... esidency certificate of United Kingdom. Since this document was filed for the first time the CIT(A) called for a remand report. In the remand report AO accepted that copy of tax residency certificate has been received and the same was issued by HM Revenue and Customs, UK in which it was declared that the assessee was a resident of the UK during the period from 06.04.2013 to 05.04.2014. AO also stated in the remand report that claim of DTAA benefit of the assessee is valid and therefore the salary income received for the work during stay at United Kingdom is exempt. CIT(A) called for a report from Ld. CIT(A)-OSD(IT) Range-2, Kolkata but the fact mentioned by the AO in the remand report stood uncontroverted. Surprisingly Ld. CIT(A) has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ax Residency Certificate, and appellant has already paid the due taxes thereon in UK, the addition wrongly made may please by deleted. 2. For that on the facts of case the remand report and the tax residency certificate issued by UK authorities, has been ignored and the claim of the appellant has been disallowed, without considering the assessment records of earlier years, wherein identical situation the relief under DTAA, has been allowed in full. 3. For that the appellant craves leave to add, alter, amend any further grounds of appeal before or at the time of hearing. 3. At the outset, the Ld. Counsel for the assessee submitted that the assessee is a non-resident Indian and claimed relief under DTAA. Due to non filing of tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... we notice that the assessee carried the matter before the Ld. CIT(A) and placed the copy of tax residency certificate of United Kingdom. Since this document was filed for the first time the Ld. CIT(A) called for a remand report. In the remand report dated 17.08.2022, the AO accepted that copy of tax residency certificate has been received on 31.08.2017 and the same was issued by HM Revenue and Customs, UK in which it was declared that the assessee was a resident of the UK during the period from 06.04.2013 to 05.04.2014. The Ld. AO also stated in the remand report that claim of DTAA benefit of the assessee is valid and therefore the salary income received for the work during stay at United Kingdom is exempt. The Ld. CIT(A) called for a repor ..... X X X X Extracts X X X X X X X X Extracts X X X X
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