ITAT Cochin Judgments — June 2023

The Tribunal found serious gaps in the facts, particularly regarding the nature of the assessee's employment (salary vs. professional fees) and the role of BSM as the payer (employer vs. agent). It noted contradictions in the TDS deduction and the NRE account receipt. Therefore, the case was remanded back to the Assessing Officer for a fresh examination of the facts, including the employer-employee relationship, the role of BSM, and the applicability of relevant sections and circulars.