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    <title>2025 (11) TMI 651 - ITAT CHENNAI</title>
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    <description>ITAT (Chennai) held the assessee was a Non-Resident under s.6(1) read with Explanation 1(a) for the four assessment years, finding employment abroad, stays in India under 182 days, and contractual service subject to foreign tax; consequently AO&#039;s additions for foreign bank deposits and foreign credit-card expenses were deleted and Revenue&#039;s appeals dismissed. Separately, additions for gifts in AY 2016-17 and AY 2018-19 were sustained where seized records showed higher gift entries than declared, the AO having jurisdiction to make additions under proceedings u/s 153A; other gift-related/addition issues were rendered academic.</description>
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      <description>ITAT (Chennai) held the assessee was a Non-Resident under s.6(1) read with Explanation 1(a) for the four assessment years, finding employment abroad, stays in India under 182 days, and contractual service subject to foreign tax; consequently AO&#039;s additions for foreign bank deposits and foreign credit-card expenses were deleted and Revenue&#039;s appeals dismissed. Separately, additions for gifts in AY 2016-17 and AY 2018-19 were sustained where seized records showed higher gift entries than declared, the AO having jurisdiction to make additions under proceedings u/s 153A; other gift-related/addition issues were rendered academic.</description>
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