https://www.taxtmi.com/caselaws?id=151933 Unexplained bank deposits in the names of Nepali residents could not be taxed as deemed income under section 69 where the treaty framework with Nepal governed the taxability first. The analysis held that articles 6 to 21 of the Double Taxation Avoidance Agreement were the relevant provisions for determining whether income was taxable, while article 22 applied only after taxability had already been established. As there was no finding that the deposits belonged to Indian residents, the treaty excluded taxation in India at that stage, and the section 69 addition was not sustainable. en-us Wed, 07 Nov 2001 00:00:00 +0530 Wed, 19 Jun 2013 18:08:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=151933 Unexplained bank deposits in the names of Nepali residents could not be taxed as deemed income under section 69 where the treaty framework with Nepal governed the taxability first. The analysis held that articles 6 to 21 of the Double Taxation Avoidance Agreement were the relevant provisions for determining whether income was taxable, while article 22 applied only after taxability had already been established. As there was no finding that the deposits belonged to Indian residents, the treaty excluded taxation in India at that stage, and the section 69 addition was not sustainable. Case-Laws Income Tax Wed, 07 Nov 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=151933