https://www.taxtmi.com/caselaws?id=799232 Non-resident income is chargeable in India only when received, accrued, arisen, or deemed to accrue or arise there; payer residence or deduction claims alone do not establish situs without a real nexus to the income-producing right or activity. Advance-ruling jurisdiction is confined to the applicant, the stated transaction and incidental questions, and tax-avoidance findings require an identifiable Indian tax incidence. Extended reassessment limitation requires a qualifying asset, transaction or entry belonging to the assessee and disclosure enabling a response. Protective assessment may resolve uncertainty over the correct assessee, but does not authorise protective recovery or indefinite withholding of TDS refunds. en-us Tue, 15 Sep 2026 00:00:00 +0530 Fri, 18 Sep 2026 07:32:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799232 Non-resident income is chargeable in India only when received, accrued, arisen, or deemed to accrue or arise there; payer residence or deduction claims alone do not establish situs without a real nexus to the income-producing right or activity. Advance-ruling jurisdiction is confined to the applicant, the stated transaction and incidental questions, and tax-avoidance findings require an identifiable Indian tax incidence. Extended reassessment limitation requires a qualifying asset, transaction or entry belonging to the assessee and disclosure enabling a response. Protective assessment may resolve uncertainty over the correct assessee, but does not authorise protective recovery or indefinite withholding of TDS refunds. Case-Laws Income Tax Tue, 15 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799232