https://www.taxtmi.com/caselaws?id=219911 The dispute concerns whether amounts received from abroad in a block assessment are taxable or correctly characterised as gifts versus rental income earned outside India. The court applied the residentialstatus sourcing principle: an assertion of Not Ordinarily Resident status does not automatically exclude Section 5 coverage; the assessee must prove income accrued or arose outside India and that no income was derived outside from an Indiacontrolled business or profession. Because the assessee failed to place material proving foreign accrual, the revenue's characterisation prevailed and taxability was upheld in favour of the revenue. en-us Wed, 22 Aug 2012 00:00:00 +0530 Tue, 03 Feb 2026 10:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219911 The dispute concerns whether amounts received from abroad in a block assessment are taxable or correctly characterised as gifts versus rental income earned outside India. The court applied the residentialstatus sourcing principle: an assertion of Not Ordinarily Resident status does not automatically exclude Section 5 coverage; the assessee must prove income accrued or arose outside India and that no income was derived outside from an Indiacontrolled business or profession. Because the assessee failed to place material proving foreign accrual, the revenue's characterisation prevailed and taxability was upheld in favour of the revenue. Case-Laws Income Tax Wed, 22 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219911