https://www.taxtmi.com/caselaws?id=236293 For India-UAE treaty purposes, the expression "otherwise liable to tax" can be satisfied by fiscal residence in the UAE even where no tax was actually paid, because treaty residence turns on fiscal domicile rather than actual levy. However, entitlement to Article 8 relief for shipping slot and related receipts depends on the precise treaty wording and the true character of the income. The Tribunal noted that slot-hire reasoning could not be applied without first determining the nature of the receipts, and in the absence of detailed findings, it remitted the matter for fresh examination by the Assessing Officer. en-us Wed, 17 Jul 2013 00:00:00 +0530 Thu, 22 Aug 2013 07:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236293 For India-UAE treaty purposes, the expression "otherwise liable to tax" can be satisfied by fiscal residence in the UAE even where no tax was actually paid, because treaty residence turns on fiscal domicile rather than actual levy. However, entitlement to Article 8 relief for shipping slot and related receipts depends on the precise treaty wording and the true character of the income. The Tribunal noted that slot-hire reasoning could not be applied without first determining the nature of the receipts, and in the absence of detailed findings, it remitted the matter for fresh examination by the Assessing Officer. Case-Laws Income Tax Wed, 17 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236293