TaxTMI 
TaxTMI 
2026 (10) TMI 268
X X X X Extracts X X X X
X X X X Extracts X X X X
....income u/s. 139(1) of the Act. The case of the assessee was reopened on the basis of credible information and notice u/s. 148 was issued. The assessee had not filed his return of income pursuant to the notice issued u/s. 148 of the Act. The AO subsequently issued notices u/s. 142(1) of the Act calling for various details. The assessee had not submitted any reply. Thereafter a show cause notice was issued and in response the assessee submitted the details of the bank statements, copy of the interest certificate issued by ICICI Bank, computation of income, passport copy and payslips of the assessee for the period under consideration. Thereafter a draft assessment order was passed. In the draft order, the AO made the observation that the salar....
X X X X Extracts X X X X
X X X X Extracts X X X X
....e NRE account of the assessee maintained with Axis Bank and therefore, the salary income earned by the assessee as a non-resident is not liable to be taxed under the provisions of the Act. The Ld.AR further submitted that the findings given by the AO as well as the Ld.DRP that the assessee had not furnished the copy of the returns filed in the foreign country and the TRC issued by the foreign country and the tax paid details in the foreign country would not be a reason for treating the salary income earned by the assessee in a foreign country as income taxable under the provisions of the Income Tax Act. The Ld.AR further submitted that the AO having accepted that the assessee had produced the details vide their submissions dated 30/05/2023 ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Industries Co. Ltd., Republic of Korea and pursuant to the agreement entered with them, the Greece company had to depute a Supervisor to supervise the construction of the vessel from September, 2014 to 30th June, 2016. In the said document, it was clearly mentioned that the Supervisor is the assessee who will work as an electrician at the project site at Korea. Pursuant to the said employment, his salary was fixed in the USD and the said amount was credited into the bank account of the assessee maintained with the Axis Bank. The bank statement copy filed by the assessee also vouched the said facts. We have also perused the copy of the passport furnished by the assessee in which several entries were made for the arrival into India and depart....