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2024 Supreme(Online)(ITAT) 1952

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
T.R. Senthil Kumar, J, Makarand V. Mahadeokar, ACJ
Assessee – Appellant
Versus
Revenue – Respondent


Advocates:
For the Appellants/Petitioners: Shri Bandish Soparkar
For the Respondents: Shri Atul Pandey

Table of Content
1. facts establish the employment and income details of the appellant. (Para 2)
2. grounds for appeal focus on assessment lag and procedural discrepancies. (Para 3 , 4)
3. court observes the delineation of jurisdiction concerning income tax on foreign employment. (Para 6 , 7 , 9)
4. key legal interpretation around 'india' concerning income from services in eez. (Para 8)

आदेश/ORDER

PER SHRI MAKARAND V. MAHADEOKAR, AM:

This appeal is filed by the Assessee as against the order passed by the Ld.Commissioner of Income-tax(Appeals)-13, Ahmedabad [hereinafter referred to as “the Ld.CIT(A)”], dated 01/06/2022, arising out of the assessment order passed by the Assessing Officer (AO) under section 143(3) r.w.s.144C(3) of the Income Tax Act, 1961 (hereinafter referred to as "the Act") dated 22/10/2021 relevant to the Assessment Year (AY) 2018-19.

Facts of the case:

2. The assessee filed his original return of income u/s.139(1) of the Act for the A.Y. 2018-19 declaring total income of Rs.16,590/-. The case was selected for scrutiny under CASS. During the course of assessment proceedings, the assessee submitted that, he is an Engineer (Under Water Inspector) working at offshore field

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