https://www.taxtmi.com/caselaws?id=471747 Article 16(1) of the India-Norway DTAA allocates taxing rights over salary for employment exercised in Norway to Norway; read with section 90(2), salary taxed there is not chargeable to tax in India. Such income cannot constitute undisclosed foreign income under the Black Money Act, which requires undisclosed foreign income or assets chargeable to tax in India; no foreign asset was identified. The asset-notice proviso permits assessment in the year of discovery only for undisclosed assets, not alleged income. Income pertaining to the relevant earlier assessment year therefore could not be assessed in a later year, rendering the proceedings without jurisdiction. en-us Fri, 24 Oct 2025 00:00:00 +0530 Wed, 16 Sep 2026 13:56:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471747 Article 16(1) of the India-Norway DTAA allocates taxing rights over salary for employment exercised in Norway to Norway; read with section 90(2), salary taxed there is not chargeable to tax in India. Such income cannot constitute undisclosed foreign income under the Black Money Act, which requires undisclosed foreign income or assets chargeable to tax in India; no foreign asset was identified. The asset-notice proviso permits assessment in the year of discovery only for undisclosed assets, not alleged income. Income pertaining to the relevant earlier assessment year therefore could not be assessed in a later year, rendering the proceedings without jurisdiction. Case-Laws Income Tax Fri, 24 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471747