← All Phrases

“non-resident”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(30) / Section 6 / ITR Forms3,736 judgments

The decision most relied on for non-resident is GE India Technology Centre Pvt. Ltd. v. CIT (327 ITR 456), cited in 663 judgments on BharatTax.

Leading authorities on non-resident

GE India Technology Centre Pvt. Ltd. v. CIT
327 ITR 456 · 2010 · Supreme Court
663
citing judgments

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

CIT v. Samsung Electronics Ltd.
345 ITR 494 · 2012 · High Court
461
citing judgments

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

Ishikawajima Harima Heavy Industries Ltd. v. DIT
288 ITR 408 · 2007 · Supreme Court
394
citing judgments

Income from offshore supply of goods and services is not taxable in India if the entire transaction, including transfer of ownership and payments, occurs outside India.

CIT v. De Beers India Minerals (P.) Ltd.
346 ITR 467 · 2012 · High Court
371
citing judgments

For fees for technical or consultancy services to 'make available' technical knowledge or know-how under a DTAA, the service must transmit such knowledge, allowing the recipient to derive an enduring benefit and utilize it independently in the future.

CIT v. Toshoku Ltd.
125 ITR 525 · 1980 · Supreme Court
270
citing judgments

A non-resident commission agent is not chargeable to tax in India on commission income if no business operations are carried out in India. Consequently, no TDS is required under Section 195 on such payments.

DIT v. Infrasoft Ltd.
39 Taxmann.com 88 · 2013 · High Court
269
citing judgments

Payments for the use of copyrighted software, without the transfer of any rights in the underlying copyright itself, do not constitute 'royalty' under the Income-tax Act or tax treaties. Such payments are often treated as business income, taxable only if a permanent establishment exists.

Transmission Corporation of Andhra Pradesh v. CIT
239 ITR 587 · 1999 · Supreme Court
243
citing judgments

The Supreme Court lays down principles for deducting tax at source (TDS) under Section 195 on payments to non-residents, including aspects of income deemed taxable in India and the application of Double Taxation Avoidance Agreements (DTAAs) under Section 90.

ONGC v. CIT
376 ITR 306 · 2015 · Supreme Court
241
citing judgments

Income derived by a non-resident for services related to mineral oil operations, falling under the presumptive taxation regime of Section 44BB, cannot simultaneously be treated as fees for technical services under Section 9(1)(vii). The specific presumptive provisions override the general FTS definition, particularly when DTAA applies.

Judgments citing non-resident

DCIT CC 8(2), Mumbai vs. Anil Dhirajlal Ambani, Mumbai

In the result, appeal of the revenue ITA No

ITA 6231/MUM/2025[2004-05]Status: DisposedITAT Mumbai09 Dec 2025AY 2004-05

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Niraj Sheth & Shri JitendraFor Respondent: Shri Rajesh Kumar Yadav (CIT DR)
Section 143(1)Section 143(3)Section 147Section 148Section 250

amount based on Base Note. In that case the assessee has not explained the contents ofthe Base Note and claimed that assessee was a non-resident and was chargeable to tax only on income which accrues or arises in India. Whereas in the case of the assessee it was explained

DCIT CC 8(2), Mumbai vs. Anil Dhirajlal Ambani, Mumbai

In the result, appeal of the revenue ITA No

ITA 6230/MUM/2025[2003-04]Status: DisposedITAT Mumbai09 Dec 2025AY 2003-04

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Niraj Sheth & Shri JitendraFor Respondent: Shri Rajesh Kumar Yadav (CIT DR)
Section 143(1)Section 143(3)Section 147Section 148Section 250

amount based on Base Note. In that case the assessee has not explained the contents ofthe Base Note and claimed that assessee was a non-resident and was chargeable to tax only on income which accrues or arises in India. Whereas in the case of the assessee it was explained

DCIT CC 8(2), Mumbai vs. Anil Dhirajlal Ambani, Mumbai

In the result, appeal of the revenue ITA No

ITA 6229/MUM/2025[2002-03]Status: DisposedITAT Mumbai09 Dec 2025AY 2002-03

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Niraj Sheth & Shri JitendraFor Respondent: Shri Rajesh Kumar Yadav (CIT DR)
Section 143(1)Section 143(3)Section 147Section 148Section 250

amount based on Base Note. In that case the assessee has not explained the contents ofthe Base Note and claimed that assessee was a non-resident and was chargeable to tax only on income which accrues or arises in India. Whereas in the case of the assessee it was explained

DCIT CC-8(2), Mumbai vs. Anil Dhirajlal Ambani, Mumbai

In the result, appeal of the revenue ITA No

ITA 6228/MUM/2025[2001-02]Status: DisposedITAT Mumbai09 Dec 2025AY 2001-02

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Niraj Sheth & Shri JitendraFor Respondent: Shri Rajesh Kumar Yadav (CIT DR)
Section 143(1)Section 143(3)Section 147Section 148Section 250

amount based on Base Note. In that case the assessee has not explained the contents ofthe Base Note and claimed that assessee was a non-resident and was chargeable to tax only on income which accrues or arises in India. Whereas in the case of the assessee it was explained

Debashis Das, Kolkata vs. ACIT-1(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 947/KOL/2023[2015-16]Status: DisposedITAT Kolkata08 Dec 2025AY 2015-16

Bench: Shri Manjunatha G & Shri Sonjoy Sarmai.T.A. No.947/Kol/2023 Assessment Year: 2015-16 Debashis Das………………………………………................................……….…Appellant Uttara Tritiya Housing Complex, Action Area-Ii, New Town, Near City Center-2, W.B– 700156. [Pan: Aixpd81639Q] Vs. Acit, International Taxaion-1(1), Kolkata ..L..….…..….......……..…...…..…..Respondent Appearances By: Shri Nishant Thakkar, Ar, Appeared On Behalf Of The Assessee. Shri Sallong Yaden, Addl. Cit-Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi For Assessment Year 2015–16. The Ld. Cit(A) Sustained The Addition Made By The Assessing Officer In Respect Of Salary Income Earned By The Assessee During His Short-Term Foreign Assignment In The Philippines. 2. The Appeal Has Been Filed By The Assessee With A Delay Of 366 Days. The Assessee Has Filed An Affidavit For Condonation Of The Delay. After Considering The Reasons Cited In The Affidavit For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 5(2)(b)Section 6(1)

days during the relevant year, and therefore, as per Section 6(1), he qualified as a non- resident. It was contended that a non-resident is taxable in India only on I.T.A. No.947/Kol/2023 Debashis Das income received or deemed to be received in India, and income accruing or arising ... placed reliance on DCIT v. Sudipta Maity reported in [2018] 96 taxman.com 336 (Kolkata-Trib), where salary for services rendered abroad by a non-resident employee of an Indian company was held not taxable in India. Judicial principle that accrual of salary is determined by the place of services rendered

Mariappan Austin Prakash, Bengaluru, Kanrnataka vs. Assistant Commissioner of Income Tax, Intl Txn Circle, Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 89/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2022-23

Bench: Shri Ravish Sood, Hon’Ble

Section 142(1)Section 143Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 195Section 9(1)(i)

dated 10.12.2024 for the A.Y. 2022-23. LT.A.No.89/VIZ/2025 Vijay Mariappan Austin Prakash = 2. Brief facts of the case are that, assessee being a Non-Resident Individual filed his return of income on 17.07.2022 admitting a taxable income of Rs.9,21,280/- and exempt income of Rs.8 ... drawing such a conclusion. Page. No4 LT.A.No.89/VIZ/2025 Vijay Mariappan Austin Prakash Bt 7. That the impugned Assessment Order is erroneous because for a non-resident, the entire tax on income chargeable to tax in India, if any, was entirely deductible at source u/s 195 of the Act and that

Nagarjuna Vutla, Eluru vs. Income-Tax Officer, Ward-1, Eluru

In the result, the appeal fails and is dismissed with costs

ITA 524/VIZ/2025[2024-25]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2024-25

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.524/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2024-25) Vs. Income Tax Officer Nagarjuna Vutla 24B-16-20, Yerakamma Street Ward-1 Ashok Nagar, Eluru Income Tax Office West Godavari District - 534002 Eluru, West Godavari District Andhra Pradesh Andhra Pradesh [Pan: Aoupn9597D]

Section 143(1)Section 246Section 246A

intimation passed under section 143(1) of the Act dated 05.02.2025. 2. Brief facts of the case are that, assessee being a Non-Resident Individual, filled his return of income on 22.07.2024 after claiming credit under Double Tax Avoidance Agreement by filing Form 67. The return was filed

M/S Informatica Business Solutions Private Limited, Bangalore vs. Joint Commissioner of Income Tax Special Rage-3, Bangalore

In the result appeal filed by the assessee is partly allowed

ITA 3356/BANG/2018[2014-15]Status: DisposedITAT Bangalore05 Dec 2025AY 2014-15

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2014-15

For Appellant: Shri Tanmayee Rajkumar, AdvocateFor Respondent: Shri Shashi Saklani, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144CSection 234BSection 271Section 274Section 28Section 37Section 40

Indonesian company in turn makes payment to employees of the assessee company after getting funds from the assessee company. He further noted that a non-resident company charges the assessee company services fee of 15% of all payments made by the assessee company to its seconded employees. The fact shows ... Indonesian company and hence the above sum was found that the seconded employees employed by the assessee company and temporarily seconded to a non-resident company for rendering services abroad. All the cost including salaries are borne by the assessee Page 12 of 18 company and paid through international company

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 303/AGR/2025[2023-24]Status: DisposedITAT Agra04 Dec 2025AY 2023-24

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

Cash credit (Gift) Assessment years 2007-08 and 2008-09 - Assessee received certain amount as gifts from his father and sister who were non-residents in India - Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors - Commissioner, however, passed

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

ITA 302/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23
Section 131Section 143(3)Section 147Section 148Section 263Section 40ASection 68

Cash credit (Gift) Assessment years 2007-08 and 2008-09 - Assessee received certain amount as gifts from his father and sister who were non-residents in India Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors Commissioner, however, passed

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 301/AGR/2025[2021-22]Status: DisposedITAT Agra04 Dec 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

Cash credit (Gift) Assessment years 2007-08 and 2008-09 - Assessee received certain amount as gifts from his father and sister who were non-residents in India - Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors - Commissioner, however, passed

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

ITA 300/AGR/2025[2019-20]Status: DisposedITAT Agra04 Dec 2025AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

Cash credit (Gift) Assessment years 2007-08 and 2008-09 - Assessee received certain amount as gifts from his father and sister who were non-residents in India Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors Commissioner, however, passed

Hma Agro Industries Limited, Agra vs. Deputy Commissioner of Income-Tax, Central Circle, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 251/AGR/2025[2018-2019]Status: DisposedITAT Agra04 Dec 2025AY 2018-2019

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

Cash credit (Gift) Assessment years 2007-08 and 2008-09 - Assessee received certain amount as gifts from his father and sister who were non-residents in India - Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors - Commissioner, however, passed

Umbrella Gold Trading Commodities Private Limited, Pune vs. ITO Ward 7(1), Pune

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2330/PUN/2025[2017-18]Status: DisposedITAT Pune04 Dec 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Umbrella Gold Trading & Ito, Ward 7(1), Pune Commodities Private Limited Laxmi Puran, Phase Ii, S Vs. No.157/A2, Yerwada, Pune – 411006 Pan: Aabcu7553N (Appellant) (Respondent) Assessee By : Shri Bhavik Chheda Department By : Smt. Indira R. Adakil, Addl.Cit Date Of Hearing : 03-12-2025 Date Of Pronouncement : 04-12-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Bhavik ChhedaFor Respondent: Smt. Indira R. Adakil, Addl.CIT
Section 143(2)Section 144Section 147Section 148Section 148ASection 151Section 37Section 69A

made cash withdrawal amounting to Rs.56,30,000/- from bank account maintained with ICICI Bank. 3. Made remittance of Rs.1,68,507/- to a non-resident or to a foreign company. 4. Since the assessee failed to disclose income from such transactions in the tax return, therefore, the Assessing Officer

Airport Retail Private Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle 12(1)(1), Mumbai

ITA 3198/MUM/2025[2017-18]Status: DisposedITAT Mumbai02 Dec 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Rajesh Kumar Yadav,CIT-DR
Section 115BSection 234Section 234BSection 250Section 271ASection 68

payment of capital to us and their capacity to subscribe to the shares 11 PAN of WDFG UK to prove the identity of the non-resident shareholder 12 Return of income filed by WDFG UK for the year ended 31 December 2016 in accordance with UK laws to prove

Anurodh Sahu, Jabalpur vs. ITO (It and Tp), Bhopal

In the result, the appeal is allowed for statistical purposes

ITA 11/JAB/2024[2018-19]Status: DisposedITAT Jabalpur28 Nov 2025AY 2018-19

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Anurodh Sahu, Vs. Ito (Ft & Tp), 3173, Tulsi Nagar Ranjhi, Jabalpur, Bhopal Madhya Pradesh Pan: Bktps9371L (Appellant) (Respondent) Assessee By: Sh. Anil Agrawal, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Income Tax Officer (It & Tp), Bhopal At Jabalpur Dated 16.01.2024 Under Section 147 R.W.S. 144C(13) Of The Income Tax Act For The A.Y. 2018-19. The Grounds Of Appeal Are As Under: - “1. That The Assessment Order Issued By The Learned Assessing Officer On The Basis Of Directions Of Drp Is Unjustified & Base Less On The Basis Of Information & Documents Submitted. 2. That The Learned Assessing Officer Has Never Countered Or Produced Before The Assessee The Source Of Information/ Documents On Basis Of Which The Said Addition Appealed Against Is Made During Whole Assessment Proceedings. 3. That The Learned Assessing Officer Never Questioned The Relevant Sources Of Income Produced & Submitted By The Assessee During The Assessment Proceedings & Brought Nothing On Record To Prove Or Justify The Assessee Having Some Other Source Or Hidden Source Of Income. 4. That The Learned Assessing Officer Has Made The Additions On The Basis Of Incomplete Information Having No Evidence & Based On Surmises On The Directions Given By Drp.

For Appellant: Sh. Anil Agrawal, C.AFor Respondent: Sh. Alok Bhura, Sr. DR
Section 147Section 148Section 271

procedure and a notice was issued on 31.03.2022. The assessee filed a return in response to this notice. The assessee was a non-resident Indian working with a foreign company namely Chevron Transport Corporation Ltd, Hamilton, Bermuda during the year. In the return of income filed, in response to notice

Prathapa Chandra Menon, Ambalappuzha vs. Assistant Commissioner, Aayakar Bhawan, Alleppey

In the result, appeal filed by the assessee is allowed

ITA 767/COCH/2025[2015-2016]Status: DisposedITAT Cochin28 Nov 2025AY 2015-2016

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Hon’Ble Manu Kumar Giriआयकर अपील सं./ Ita No.767/Coch/2025 "नधा"रण वष" /Assessment Year: 2015-16 Prathapa Chandra Menon, The Asst. Commissioner Of Menon Mar Madom, Vs. Income Tax, Ambalapuzha Fast Edb.O, Alappuzha. Ambalappuzha, Alappuzha – 688 561. Pan: Cmzpm 2672R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : None ""यथ" क" ओर से /Respondent By : Smt. Leena Lal, Snr A.R सुनवाई क" तार"ख/Date Of Hearing : 06.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 28.11.2025 आदेश / O R D E R Per Manu Kumar Giri ():

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr A.R
Section 271F

penalty has been wrongly levied despite the fact that the assessee had no taxable income for the relevant assessment year. The assessee is a non-resident, and the statutory notices allegedly issued by the AO were never received. The non-filing of return and non-response to notices were ... beyond the assessee’s control. The penalty order violates the principles of natural justice. 3. Facts of the case is that the assessee, a non-resident individual, did not file a return of income for A.Y. 2015-16. The Assessing Officer issued penalty proceedings u/s 271F and imposed a penalty

Vinod Ojha, Hyderabad vs. Income Tax Officer, Ward-5(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1231/HYD/2024[2016-17]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1231/Hyd/2024 (िनधा"रण वष"/Assessment Year 2016-2017) Vinod Ojha, The Income Tax Officer, Ward-5(1), Hyderabad-500012. Vs. Hyderabad – 500 057. Telangana. Telangana. Pan Aahpo3171F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Kumar Pal Tated राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr

For Appellant: CA Kumar Pal TatedFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 139(1)Section 144Section 147Section 148Section 149

submissions of both the parties and perused the material available on record. There is no dispute between the parties that the assessee is a Non-Resident Indian. Admittedly, in the instant case, the assessment has been reopened u/sec.147 of the Act by issuance of notice u/sec.148

Sanjay Dutt, New Delhi vs. ACIT, Circle 1(2)(2), International Taxation, New Delhi

In the result, impugned order is set aside and appeal of the assessee is allowed

ITA 1857/DEL/2022[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Vikas Awasthy& Shri M. Balaganeshआअसं.1857/िद"ी/2022(िन.व. 2018-19) Sanjay Dutt, Bl Gupta & Co. 103 Ff, Caxton House, Khandewalan Extn., New Delhi 110055 ...... अपीलाथ"/Appellant Pan No: Aeqpd-5870-F बनाम Vs. Assistant Commissioner Of Income Tax, ....."ितवादी/Respondent Circle 1(2)(2), New Delhi 110002

For Appellant: Ms. Manju Goel & Shri B.L Gupta, Chartered AccountantsFor Respondent: Shri M.S Nethrapal, CIT-DR
Section 143(3)Section 2(47)Section 2(47)(v)Section 53A

year of taxation of capital gains. 2.1. Narrating facts of the case, the ld. AR of the assessee submits that the assessee is a non-resident. The assessee entered into Property Development Agreement (PDA) with Sanskar Home P. Ltd. (Developer) on 14.06.2017 with respect 2 to property bearing

Manoj Arjun Nasta, Mumbai - Currently Resident in Uae vs. Income Tax Offcer Ward 42(2)(4), Ward 42(2)(4)

In the result, the appeal of the assessee in ITA No

ITA 5809/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Nov 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(b)Section 271(1)(c)

Assessing Officer towards the alleged unexplained investment in the purchase of immovable property. The learned counsel submitted that the assessee has been a Non-Resident Indian for several decades, permanently employed abroad and earning income outside India. Being a non-resident, he was not filing his return of income ... close examination of the facts and circumstances, we find considerable force in the explanation furnished. The assessee, being a long-standing non-resident, was not filing a return in India and therefore had no occasion or expectation to monitor communications from the Income-tax Department 3 ITA No.5807-5809/Mum/2025 Manoj Arjun