https://www.taxtmi.com/caselaws?id=787363 Taxability of consultancy receipts in a non-resident individual's hands required proof of a taxable nexus in India, such as a permanent establishment, fixed base, or business connection. The Tribunal found no direct or indirect evidence that the services were rendered from India, no material change from the earlier year, and no basis to tax the amount as business income, fees for technical services, or under the India-UAE DTAA. Investments made by separate foreign group companies could not be attributed to the shareholder without reliable evidence showing that he himself made the investments or that corporate personality should be disregarded. Both additions were deleted. en-us Thu, 26 Feb 2026 00:00:00 +0530 Tue, 03 Mar 2026 08:42:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787363 Taxability of consultancy receipts in a non-resident individual's hands required proof of a taxable nexus in India, such as a permanent establishment, fixed base, or business connection. The Tribunal found no direct or indirect evidence that the services were rendered from India, no material change from the earlier year, and no basis to tax the amount as business income, fees for technical services, or under the India-UAE DTAA. Investments made by separate foreign group companies could not be attributed to the shareholder without reliable evidence showing that he himself made the investments or that corporate personality should be disregarded. Both additions were deleted. Case-Laws Income Tax Thu, 26 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787363