https://www.taxtmi.com/caselaws?id=188956 An advance ruling application was maintainable because the valid filing date was when the applicant was a non-resident in the preceding financial year. For treaty purposes under Article 4 of the India-UAE DTAA, residence was determined by the tie-breaker sequence of permanent home, centre of vital interests and habitual abode; with no clear centre of vital interests, habitual abode in Abu Dhabi made the applicant a UAE resident. As a result, dividend income from Indian companies was taxable in India at 15% of the gross amount, interest income from Indian sources at 12.5%, and capital gains on movable assets such as shares, debentures, units and other securities were taxable only in the UAE. en-us Thu, 01 Aug 1996 00:00:00 +0530 Wed, 21 Dec 2016 18:09:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=188956 An advance ruling application was maintainable because the valid filing date was when the applicant was a non-resident in the preceding financial year. For treaty purposes under Article 4 of the India-UAE DTAA, residence was determined by the tie-breaker sequence of permanent home, centre of vital interests and habitual abode; with no clear centre of vital interests, habitual abode in Abu Dhabi made the applicant a UAE resident. As a result, dividend income from Indian companies was taxable in India at 15% of the gross amount, interest income from Indian sources at 12.5%, and capital gains on movable assets such as shares, debentures, units and other securities were taxable only in the UAE. Case-Laws Income Tax Thu, 01 Aug 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=188956