India Can't Tax Unexplained Investments from UAE Sources Due to Indo-UAE Tax Treaty Terms.

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....Income accrued/taxable in India - Tax Resident - unexplained investment of the assessee made from the undisclosed sources - since, under the terms of the Indo UAE tax treaty, the right to tax the amounts in question, even if that be of income nature in the hands of the present assessee, does not belong to India, all these issues being raised by the learned counsel are wholly academic as of now. - AT....