关于Objection of amended assessment

zeroe

请大家帮帮忙，这道题要怎么做？

In May 2009 Mr Singh left his family and his family home in Perth to move to Dubai to work as site engineer for a Danish engineering company, Markuson AS (“MAS”), pursuant to a 2-year contract with an option to extend for two further periods of six months each.
Relevantly, Mr Singh was born in India in 1965 and emigrated to Australia in 1989 with his wife and two children. They all became Australian citizens in 2003. In 2003 Mr Singh jointly purchased a house in Perth with his wife which is mortgaged to the National Bank of Australia. In April 2008 MAS offered Mr Singh a “temporary employment” contract  (the “Contract”) as “Site Engineering Manager” to be located in Dubai. The term of Contract was from May 2008 to May 2010.
Mr Singh accepted the Contract in late April 2008 and as a result obtained a three-year “work residency visa”, enabling him to live and work in Dubai. The Contract related to a specific project referred to as “Package 10”, involving the construction and installation of oil and gas platforms. This was one of 17 other Packages comprising the entire project undertaken by MAS in Dubai.
The Contract could be terminated by either party upon the giving of one month’s prior notice with MAS agreeing to pay airfares, the rent for a serviced apartment in Dubai and to provide Mr Singh with a car for the duration of his Contract. However, Mr Singh was required to purchase food and household requisites and had employed a maid and gardener at his own expense.
Mr Singh’s wife and children visited him three times while he was in Dubai, staying approximately two months on each occasion. Mr Singh also briefly visited and holidayed with his family in Australia during the Contract period. As well, Mr Singh maintained an Australian bank account to which his wife had access and he used almost all of the money he earned under the Contract to reduce the mortgage on his Perth home.
Mr Singh returned to Australia to live with his wife and children in the family home in December 2010. In 2011 he was served with an amended notice of assessment by the Australia Taxation Office which included the amount he earned while working in Dubai between 2008 and 2010. Mr Singh wishes to object to the amended assessment and seeks your advice as to whether the ATO is justified in taxing him on his Dubai income.

Your advice must explain the basis on which the ATO would be seeking to tax Mr Singh’s Dubai income

zeroe

  help ^^^^^^^