<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2026 (2) TMI 867 - ITAT AHMEDABAD</title>
    <link>https://www.taxtmi.com/caselaws?id=786719</link>
    <description>The note addresses whether salary earned by a non-resident for services rendered outside India and later credited to an NRE account constitutes &#039;income received in India&#039; under Section 5(2)(a). It applies the constructive-receipt principle, holding that receipt occurs on the first occasion the assessee obtains control abroad and that subsequent remittance or credit into an Indian account is merely application of pre-existing foreign income; therefore the credited salary is not taxable. Consequentially, additions for unexplained foreign-currency investment and unexplained bank credits founded on the deleted salary finding were also deleted.</description>
    <language>en-us</language>
    <pubDate>Mon, 09 Feb 2026 00:00:00 +0530</pubDate>
    <lastBuildDate>Wed, 18 Feb 2026 08:11:59 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=886880" rel="self" type="application/rss+xml"/>
    <item>
      <title>2026 (2) TMI 867 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=786719</link>
      <description>The note addresses whether salary earned by a non-resident for services rendered outside India and later credited to an NRE account constitutes &#039;income received in India&#039; under Section 5(2)(a). It applies the constructive-receipt principle, holding that receipt occurs on the first occasion the assessee obtains control abroad and that subsequent remittance or credit into an Indian account is merely application of pre-existing foreign income; therefore the credited salary is not taxable. Consequentially, additions for unexplained foreign-currency investment and unexplained bank credits founded on the deleted salary finding were also deleted.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Mon, 09 Feb 2026 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=786719</guid>
    </item>
  </channel>
</rss>