Non-resident cannot be taxed in India unless income is proven to accrue or arise within India

DCIT Vs Vimal Kanubhai Patel (ITAT Ahmedabad) Introduction: In the recent case of DCIT vs. Vimal Kanubhai Patel, the Income Tax Appellate Tribunal (ITAT) in Ahmedabad addressed a significant dispute concerning the addition of INR 3,45,90,531/- on account of unexplained credits in the Citibank NA Singapore account for the Assessment Year 2004-05. The Revenue, dissatisfied with the order of the Commissioner of Income-tax (Appeals) [CIT(A)], appealed against the decision. Background: Vimal Kanubhai Patel, an individual and non-resident for the relevant assessment year, was a director in various c...