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    <title>2022 (11) TMI 530 - ITAT MUMBAI</title>
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    <description>The Tribunal invalidated the reopening of assessment due to lack of credible evidence and independent application of mind by the Assessing Officer. The additions to the assessee&#039;s income based on the &#039;base note&#039; were deleted as the AO failed to prove the income in the foreign bank account was taxable in India. The Tribunal confirmed that non-residents are only taxable in India if income is sourced from India. The appeals by the AO were dismissed, and the CIT(A)&#039;s decision to delete the additions was upheld for both assessment years.</description>
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      <title>2022 (11) TMI 530 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=430106</link>
      <description>The Tribunal invalidated the reopening of assessment due to lack of credible evidence and independent application of mind by the Assessing Officer. The additions to the assessee&#039;s income based on the &#039;base note&#039; were deleted as the AO failed to prove the income in the foreign bank account was taxable in India. The Tribunal confirmed that non-residents are only taxable in India if income is sourced from India. The appeals by the AO were dismissed, and the CIT(A)&#039;s decision to delete the additions was upheld for both assessment years.</description>
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