https://www.taxtmi.com/caselaws?id=467007 Consultancy receipts routed through foreign companies cannot be taxed in the assessee's hands in India merely on allegation of a permanent establishment, fixed base, or business connection; the record lacked credible evidence that the services were performed from India, that the premises were at the assessee's disposal, or that treaty conditions for taxing business profits or professional income were met. Investment amounts standing in the names of separate foreign companies also cannot be assessed as unexplained investment in the assessee's hands without concrete material showing that he personally made the investments from undisclosed sources. The legal position emphasised is that taxability cannot rest on presumption, shareholder status, or alleged conduit arrangements without proof of nexus. en-us Tue, 30 Apr 2024 00:00:00 +0530 Sat, 28 Feb 2026 12:24:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467007 Consultancy receipts routed through foreign companies cannot be taxed in the assessee's hands in India merely on allegation of a permanent establishment, fixed base, or business connection; the record lacked credible evidence that the services were performed from India, that the premises were at the assessee's disposal, or that treaty conditions for taxing business profits or professional income were met. Investment amounts standing in the names of separate foreign companies also cannot be assessed as unexplained investment in the assessee's hands without concrete material showing that he personally made the investments from undisclosed sources. The legal position emphasised is that taxability cannot rest on presumption, shareholder status, or alleged conduit arrangements without proof of nexus. Case-Laws Income Tax Tue, 30 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467007