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    <title>2026 (3) TMI 956 - BOMBAY HIGH COURT</title>
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    <description>Foreign bank deposits of a non-resident were held not taxable in India because the Revenue failed to prove that the amounts were received, accrued, or arose in India, or were otherwise within the charging provisions applicable to non-residents. The Court relied on concurrent factual findings that the deposits were in an overseas account and that the materials did not establish an Indian source or any sufficient nexus with taxable income in India. The addition was therefore unsustainable, and the Revenue&#039;s challenge failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=788201</link>
      <description>Foreign bank deposits of a non-resident were held not taxable in India because the Revenue failed to prove that the amounts were received, accrued, or arose in India, or were otherwise within the charging provisions applicable to non-residents. The Court relied on concurrent factual findings that the deposits were in an overseas account and that the materials did not establish an Indian source or any sufficient nexus with taxable income in India. The addition was therefore unsustainable, and the Revenue&#039;s challenge failed.</description>
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