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Tax Publishers
Bonus of a non-resident received when he became a
resident - denial of tax credit
Facts:
Assessee
was a non-resident who was employed in Singapore. Post facto his employment he
became a resident in the year of appeal. He was in receipt of bonus from his non-resident
employer on which TDS was done as per Singapore Income tax law. AO and CIT(A)
denied the tax credit of the taxes paid in Singapore to the assessee. On appeal
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Held
in favour of the assessee that once the bonus amount becomes taxable in India
as well due to residency and there were taxes which were deducted in Singapore
on the same, assessee was entitled to full credit of the TDS done in Singapore.
Case: Souvik Mukherjee v. ITO 2023 TaxPub(DT) 4051 (Del-Trib)
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