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The case pertains to the reopening of assessment u/s 147 regarding income related to a Non-Resident External (NRE) Account. The assessee argued that the source of income and deposits were from the NRE Account, and therefore, not taxable in India. The bank details and statements provided by the assessee revealed that the remittance of the loan was made from the NRE Account, substantiating the source of income. As per Section 10(4)(ii) of the Income Tax Act, income earned in an NRE Account is exempt from taxation. Considering the assessee's explanation supported by bank statements, the court found no justification for issuing a notice u/s 148 or passing an order u/s 148A(d) of the Act regarding the reopening of assessment.
The case pertains to the reopening of assessment u/s 147 regarding income related to a Non-Resident External (NRE) Account. The assessee argued that the source of income and deposits were from the NRE Account, and therefore, not taxable in India. The bank details and statements provided by the assessee revealed that the remittance of the loan was made from the NRE Account, substantiating the source of income. As per Section 10(4)(ii) of the Income Tax Act, income earned in an NRE Account is exempt from taxation. Considering the assessee's explanation supported by bank statements, the court found no justification for issuing a notice u/s 148 or passing an order u/s 148A(d) of the Act regarding the reopening of assessment.
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