Income accrual for non-residents requires a real Indian nexus, defeating reassessment where rights and activity are overseas.

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....Taxability of non-resident receipts depends on a real and substantive nexus between India and the income-producing right or activity, or on a specific statutory deeming provision; an Indian payer's residence, accounting treatment, expenditure claim or remittance alone is insufficient. Overseas contractual rights, settlement and market exploitation do not create Indian accrual merely through foreign anti-trust allegations unsupported by a judicial finding or admission. Advance-ruling jurisdiction is confined to the applicant and transaction, and prima facie tax avoidance requires an identified Indian tax incidence. Extended reassessment limitation requires a qualifying asset belonging to the assessee and prior meaningful opportunity on that .........