The assessee's income earned in the USA is taxable in India. The ...

Taxability of income earned abroad based on centre of vital interests.

December 18, 2024

Case Laws Income Tax AT

The assessee's income earned in the USA is taxable in India. The tie-breaker test under Article 4 of the India-US DTAA is not applicable, as the assessee's centre of vital interest remained in India. While the income is includable in the total income u/s 5 of the Income Tax Act, the Appellate Tribunal directed the Assessing Officer to grant credit for taxes paid abroad by the assessee on the same income to avoid double taxation.

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The assessee's income earned in the USA is taxable in India. The ...

Taxability of income earned abroad based on centre of vital interests.

December 18, 2024

Case Laws Income Tax AT

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