https://www.taxtmi.com/caselaws?id=786719 For a non-resident, income is "received in India" only when first obtained in the taxpayer's real or constructive control. Salary earned and constructively received outside India for services rendered outside India does not become taxable under Section 5(2)(a) merely because it is later remitted or credited to an NRE account in India; such credit is an application of an existing foreign receipt, not a fresh Indian receipt. Where foreign-sourced salary explains funds used for foreign-currency purchases and bank credits, additions treating those amounts as unexplained lack a factual basis and are deleted. en-us Mon, 09 Feb 2026 00:00:00 +0530 Wed, 18 Feb 2026 08:11:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786719 For a non-resident, income is "received in India" only when first obtained in the taxpayer's real or constructive control. Salary earned and constructively received outside India for services rendered outside India does not become taxable under Section 5(2)(a) merely because it is later remitted or credited to an NRE account in India; such credit is an application of an existing foreign receipt, not a fresh Indian receipt. Where foreign-sourced salary explains funds used for foreign-currency purchases and bank credits, additions treating those amounts as unexplained lack a factual basis and are deleted. Case-Laws Income Tax Mon, 09 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786719