Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT held that salary income received by non-resident assessee for services rendered outside India is not taxable in India. Revenue authorities failed to establish that income accrued or originated in India despite assessee receiving salary both domestically and abroad. Tribunal found no evidence demonstrating Indian source of income for foreign services. Following precedent in Manab Chandra Ghosh, ITAT determined that foreign assignment allowances for services performed outside India cannot be taxed in India absent proof of Indian accrual. CIT(A) order set aside, directing AO to delete the addition. Assessee's appeal allowed, confirming non-taxability of foreign-sourced employment income for non-resident taxpayers.
ITAT held that salary income received by non-resident assessee for services rendered outside India is not taxable in India. Revenue authorities failed to establish that income accrued or originated in India despite assessee receiving salary both domestically and abroad. Tribunal found no evidence demonstrating Indian source of income for foreign services. Following precedent in Manab Chandra Ghosh, ITAT determined that foreign assignment allowances for services performed outside India cannot be taxed in India absent proof of Indian accrual. CIT(A) order set aside, directing AO to delete the addition. Assessee's appeal allowed, confirming non-taxability of foreign-sourced employment income for non-resident taxpayers.
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