Income earned abroad as Non Resident cannot be taxed in India for mere receipt in Indian Bank A/c

Pramod Kumar Sapra Vs. Income Tax Officer (ITAT Delhi) Observation that since the salary income has been received in India, i.e., it has been credited in the bank account of the assessee in India and also TDS has been deducted by the employer, this fact cannot be a determinative of the taxability of resident or non-resident in terms of provisions of the Act. What is relevant is, whether the income can be said to be received or deemed to be received in India. Sub-section (2) of section 5 merely provides that total income of any previous year of a non-resident includes all income from whatever s...