https://www.taxtmi.com/highlights?id=97825 Territorial nexus limits taxation of a non-resident's foreign bank deposits: amounts held abroad are taxable in India only if received or deemed received in India, or if they accrue/arise or are deemed to accrue/arise in India; Sections 5(2) and 9 cannot be stretched to tax sums outside India. The Revenue bore the burden to prove Indian sourcing of deposits and failed to discharge that onus (ei qui affirmat incumbit probatio), so additions could not be sustained. Re taxing income already subjected to tax in other hands or years is impermissible, supporting deletion of the addition and dismissal of the appeal. en-us Wed, 18 Mar 2026 08:21:00 +0530 Wed, 18 Mar 2026 08:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97825 Territorial nexus limits taxation of a non-resident's foreign bank deposits: amounts held abroad are taxable in India only if received or deemed received in India, or if they accrue/arise or are deemed to accrue/arise in India; Sections 5(2) and 9 cannot be stretched to tax sums outside India. The Revenue bore the burden to prove Indian sourcing of deposits and failed to discharge that onus (ei qui affirmat incumbit probatio), so additions could not be sustained. Re taxing income already subjected to tax in other hands or years is impermissible, supporting deletion of the addition and dismissal of the appeal. Highlights Income Tax Wed, 18 Mar 2026 08:21:00 +0530 https://www.taxtmi.com/highlights?id=97825