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Department Must Substantiate Shell Company Claim Despite: ITAT Delhi

Even though the department had the authority to dispute the residential status of the assessee merely on the strength of the Tax Residency Certificate (TRC), it was incumbent upon the department to make a proper inquiry and to establish the fact that the party claiming benefit and the strength of the TRC was a shell or conduit company.

Dept Can Dispute Residential Status On Strength Of TRC But Not Without Establishing Assessee To Be Shell Company: ITAT

The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has held that though the department has the authority to dispute the residential status of the assessee merely on the strength of the Tax.

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Navigating Tax Residency: A Guide for South African Expats

Navigating Tax Residency: A Guide for South African Expats
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