tier tribunal considered the
interpretation of the double tax treaty between the UK and Israel and In
particular the meaning of the phrase "subject ... Article XI of the UK-Israel
double tax treaty provides that UK sourced pensions will not be subject to UK tax
where they are received
tier tribunal considered the interpretation of the double tax treaty
between the UK and Israel and in particular the meaning of the phrase "subject ... Article XI
of the UK-Israel double tax treaty provides that UK sourced pensions will not be subject to UK tax
where they are received
account from his son, who also was a non-resident
residing in UK and therefore since no income had accrued or received or
earned ... made from remittances received from his
son who has earnings from Spain, UK and parts of Europe i.e. outside India.
It was submitted that
account from his son, who also was a non-resident
residing in UK and therefore since no income had accrued or received or
earned ... made from remittances received from his
son who has earnings from Spain, UK and parts of Europe i.e. outside India.
It was submitted that
Trust valued
at Rs.34,65,22,917/- and UK Trust valued at Rs.20,55,59,640/- as wealth in the hands ... erred in
deleting the wealth of the USA and UK trust amounting to Rs.
34,65,22,917 and Rs. 20,55,59,640/- respectively
Gandhidham-Kutch Gandhidham.
(अपीलाथ /Appellant) Agent of M/s IAL Container
Line (UK).
PAN:AABCI1414L
यथ /Respondent
राज व क ओर से/ Revenue by Shri ... freight beneficiary of M/s IAL Container Lines (UK) Ltd
without paying freight tax. The AO for the sake of convenience and since the
issue
view that the assessee has claimed incorrect
benefit of DTAA with UK since the non-resident recipient was not a
resident of UK ... that the payee was Tax resident of
British virgin Island and not UK and this fact was not disclosed to RBI or
to its Auditors
view that the assessee has claimed incorrect
benefit of DTAA with UK since the non-resident recipient was not a
resident of UK ... that the payee was Tax resident of
British virgin Island and not UK and this fact was not disclosed to RBI or
to its Auditors
view that the assessee has claimed incorrect
benefit of DTAA with UK since the non-resident recipient was not a
resident of UK ... that the payee was Tax resident of
British virgin Island and not UK and this fact was not disclosed to RBI or
to its Auditors
view that the assessee has claimed incorrect
benefit of DTAA with UK since the non-resident recipient was not a
resident of UK ... that the payee was Tax resident of
British virgin Island and not UK and this fact was not disclosed to RBI or
to its Auditors