https://www.taxtmi.com/caselaws?id=217329 Treaty benefits under the Indo-Canada DTAA were denied where the assessee failed to produce documentary proof of Canadian tax residency and citizenship alone was held insufficient for treaty purposes; the Tribunal also treated the claim as lacking bona fides in light of the surrounding facts. In the same matter, repeated adjournments, withdrawal of active representation, and the assessee's non-cooperation led the Tribunal to treat the cross objections as not being pursued and dismiss them for non-prosecution. The discussion also refers to assessment reopening based on discovered material, though the operative focus remained on tax residency proof, treaty entitlement, and failure to prosecute. en-us Fri, 18 May 2012 00:00:00 +0530 Thu, 11 Oct 2012 08:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217329 Treaty benefits under the Indo-Canada DTAA were denied where the assessee failed to produce documentary proof of Canadian tax residency and citizenship alone was held insufficient for treaty purposes; the Tribunal also treated the claim as lacking bona fides in light of the surrounding facts. In the same matter, repeated adjournments, withdrawal of active representation, and the assessee's non-cooperation led the Tribunal to treat the cross objections as not being pursued and dismiss them for non-prosecution. The discussion also refers to assessment reopening based on discovered material, though the operative focus remained on tax residency proof, treaty entitlement, and failure to prosecute. Case-Laws Income Tax Fri, 18 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217329