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ITAT allowed the assessee's appeal, holding that amounts standing to credit in a foreign bank account cannot be taxed absent a real and intimate business connection with India. The Tribunal found no direct evidence of business activity in India and rejected the DRP's contention that an Indian address or mere credit in the HSBC Geneva account established a taxable nexus. The impugned addition under the Income Tax Act was set aside for lack of legal basis and requisite causal link between any activity in India and accrual of income to the non-resident. Directions were issued to delete the addition and restore the assessment accordingly.
ITAT allowed the assessee's appeal, holding that amounts standing to credit in a foreign bank account cannot be taxed absent a real and intimate business connection with India. The Tribunal found no direct evidence of business activity in India and rejected the DRP's contention that an Indian address or mere credit in the HSBC Geneva account established a taxable nexus. The impugned addition under the Income Tax Act was set aside for lack of legal basis and requisite causal link between any activity in India and accrual of income to the non-resident. Directions were issued to delete the addition and restore the assessment accordingly.
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