1. 1. Background:
1.1 Miss ABC (‘querist’) is a Green card holder since May 2006 of USA but citizen of India. On account of fear of acute pandemic in New York (NY), she came to Mumbai under the Vande Bharat program on 27th June, 2020 (flight from NY on 26th June, 2020). Prior to that she has been living in NY since August 2018 for work at multinational Bank and living in US since August 2016 for MBA studies.
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1. Taxation in India:
1.1 The Finance Act, 2015 has incorporated Chapter XII-FB “Special provisions relating to tax on income of investment funds and income received from such funds”. These provisions are specified in section 115UB and sections 10(23FBA) / 10(23FBB)
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1. Background 1.1 XYZ Insurance Company Ltd. (‘XYZ’) is one of India’s leading life insurance company. As a measure of risk mitigation and transfer, it has entered into a reinsurance contract in the form of Treaty Insurance with ABC Reinsurance Company Limited, Switzerland (‘ABC Re’) which is a leading global wholesale provider of reinsurance. ABC
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1.Background Shri XYZ, an Indian citizen, has stayed in India for a period of 170 days and gone abroad for an employment with Singapore Company during the previous year 2011-2012 relevant to Assessment Year 2012-2013. During the said year, he has made 7 trips abroad and his aggregate stay in India was 170 days
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1.Background XYZ -Singapore (Singapore Company) is a company registered in Singapore doing jobs in India for various contracts for XYZ-India, an Indian Company and also for other companies in India. Both XYZ-Singapore and XYZ-India are related parties and also group Companies. Thus Singapore Company is liable comply with the Indian taxation laws as applicable
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