https://www.taxtmi.com/caselaws?id=428928 Unexplained investment cannot be taxed in India under section 69 where the assessee is a UAE tax resident and no material shows that the amount arose from income earned in India. The residuary allocation under article 22 of the India-UAE DTAA leaves taxing rights with the residence jurisdiction for income not otherwise specifically dealt with, and India cannot claim tax merely because the investment was made in India. In the absence of proof of an Indian source or economic nexus, the addition was not sustainable and was deleted. en-us Tue, 11 Oct 2022 00:00:00 +0530 Fri, 14 Oct 2022 08:48:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428928 Unexplained investment cannot be taxed in India under section 69 where the assessee is a UAE tax resident and no material shows that the amount arose from income earned in India. The residuary allocation under article 22 of the India-UAE DTAA leaves taxing rights with the residence jurisdiction for income not otherwise specifically dealt with, and India cannot claim tax merely because the investment was made in India. In the absence of proof of an Indian source or economic nexus, the addition was not sustainable and was deleted. Case-Laws Income Tax Tue, 11 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428928