Tax on income earned by celebrity in Canada

One of my clients participated in a cultural programme in Canada and earned income of $5,000. My client is ‘resident and ordinarily resident’ in India. This income, according to DTAA between India and Canada is taxable in the contracting State of source and not in the contracting State of residence. The AO (Assessing Officer) however refuses to accept Article 18 of DTAA which, in my view, favours my client. How to proceed further?

Revised return after receipt of reassessment notice

Our company filed return of income for the assessment year 2006-07 in July 2006. The return was revised subsequently in December 2006 claiming deduction for the voluntary retirement payments which were not claimed in the original return. In January 2008 we received a notice under section 148 for disallowance of depreciation in respect of one of the undertakings which had not functioned during the financial year 2005-06. We filed a return in response to the notice under section 148 and now, before completion of assessment, we would like to file yet another revised return. Is it possible?

Absence of voting rights in mutual association

We have a recreation club meant for members only. Members pay annual membership fee and also pay for the services used in the club. The income of the club is not distributed to the members and we have been outside the tax net on the ground of mutuality. To increase the number of members, we have decided to amend our regulations and create yet another class of members without voting rights. However, they would be eligible for the facilities available in the club. Members also bring their friends and relatives as ‘guests’ to our club and the club raises bill in the name of members even for the services utilized by the guests. Is the principle of mutuality affected by permitting the guests to enjoy the facilities in our club? Would the proposed move to induct members without voting rights impact the application of mutuality principle?

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