Tribunal Limits Taxation to India for Non-Residents; Reverses Land Filling Expense Disallowance Due to TDS Rules.

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....Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s decision, noting the AO had treated the assessee as a non-resident and that the global income would only be taxable in India if it accrued or arose in India. - Further, the Tribunal reversed the CIT(A)'s decision on the disallowance of land filling expenses, accepting the assessee's argument regarding non-applicability of TDS deduction requirements due to not being under tax audit as per section 44AB in the preceding year.....