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Dec 08, 2025
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UAE-based taxpayer earned Rs 4 crore income in India on which TDS was deducted but he didn't file ITR, got tax notice; wins case in ITAT Delhi
On November 19, 2025, the Income Tax Appellate Tribunal ruled that if a non-resident taxpayers' total income from India consists solely of dividends, interest, etc (known as Section 115A incomes) and TDS has been deducted from these incomes, then not filing an ITR is not considered as income escapement.
This ruling (ITA No.6152/Del/2024) came into force in a case filed by a non-resident taxpayer who had a dispute with Indian tax authorities over not filing an income tax return (ITR) even after earning Rs 4 crore in interest income from India.
In brief, the entity involved is a tax resident of the United Arab Emirates (UAE). This taxpayer earned an interest income of 7.48 lakh USD (Rs 4.247 crore) from IIFCO, an Indian company.
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