Pradip J. Mehta vs Commissioner Of Income Tax,Ahmedabad

The Supreme Court upheld the High Court's decision affirming the Income Tax Appellate Tribunal's interpretation of Section 6(6) of the Income Tax Act, 1961, regarding the status of the assessee as 'not ordinarily resident' for the assessment year 1982-83. The Court found that the assessee did not meet the criteria set forth in Section 6(6)(a) as he had been resident in India for more than 730 days during the relevant period. Consequently, the appeal was dismissed, affirming the Tribunal's ruling that the assessee was not entitled to exclude foreign income from total income under Section 5(1)(c).