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2021 (6) TMI 365 - ITAT HYDERABADLevy of tax on interest income - Status of the assessee - Resident but not ordinarily resident - NRI Account - Receipts brought in India - source of income earned outside India - HELD THAT:- As decided in own case [2015 (3) TMI 755 - ITAT HYDERABAD] provisions of Section 5(2) are also not applicable as the amount received is received from assessee's own account outside India and no income has accrued or arisen in India. These funds were also received through banking channels with necessary statutory approvals. Therefore, assessee has proved the sources of receipts and discharged the onus. It is the Revenue which failed in proving that this amount is unexplained income of assessee. We are of the opinion that various case laws relied by the Revenue does not apply and they are clearly distinguishable. In view of this, we have no hesitation in upholding the order of the CIT(A) and rejecting the Revenue's grounds.
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