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    <title>1999 (1) TMI 537 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>The case involved a U.S. citizen employed by Whirlpool Corporation in India for 76 days during a financial year. The court determined the applicant&#039;s non-resident status for tax purposes. Relying on the Double Taxation Avoidance Agreement between the U.S.A. and India, the court concluded that the applicant, whose salary was paid by a foreign employer and not borne by a permanent establishment in India, was not liable to tax in India. Consequently, the court did not address other questions regarding the applicant&#039;s tax liability or evaluation of provided amenities. The ruling favored the applicant based on the treaty provisions and specific circumstances.</description>
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    <pubDate>Mon, 18 Jan 1999 00:00:00 +0530</pubDate>
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      <title>1999 (1) TMI 537 - AUTHORITY FOR ADVANCE RULINGS</title>
      <link>https://www.taxtmi.com/caselaws?id=189754</link>
      <description>The case involved a U.S. citizen employed by Whirlpool Corporation in India for 76 days during a financial year. The court determined the applicant&#039;s non-resident status for tax purposes. Relying on the Double Taxation Avoidance Agreement between the U.S.A. and India, the court concluded that the applicant, whose salary was paid by a foreign employer and not borne by a permanent establishment in India, was not liable to tax in India. Consequently, the court did not address other questions regarding the applicant&#039;s tax liability or evaluation of provided amenities. The ruling favored the applicant based on the treaty provisions and specific circumstances.</description>
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      <pubDate>Mon, 18 Jan 1999 00:00:00 +0530</pubDate>
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