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1. 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...

2. Residence in India - Residential status - Status of the assessee as “Resident” of India - calculation of days of stay in India - inclusion of date of arrival in counting...

3. Income deemed to accrue or arise in India - residential status of the assessee under the India-USA DTAA. Assessee stayed in India for more than 183 days, considered a...

4. Resident of India - number of days of stay in India - a citizen of India, or a person of Indian origin - if the assessee comes to a visit in India, the requirement of...

5. Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s...

6. 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...

7. The issue pertains to whether the amounts received as sales commission by a non-resident assessee are in the nature of fees for included services, and whether such...

8. Income accrued in India - Benefit of India-UK Tax Treaty - Whether the assessee has PE in India and the receipts are liable to be taxed as ‘Business Profits’? - if the...

9. Income deemed to accrue or arise in India - PE in India - employees of the assessee were present in India for rendering services for a period aggregating to only 13 days...

10. 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...

11. Validity of reopening of assessment u/s 147 - Income accrued in India - Assessee had shifted to the United States - period of stay in India - Since the assessee did not...

12. Residential Status of assessee - when his stay in India during the relevant period was only 68 days which is much less than the period of 182 days as per statutory...

13. 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...

14. Determination of residential status of assessee - Relaxation of period of 60 days as per section 6(1)(a) to 182 days when employment is taken outside India as per clause...

15. Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e...