https://www.taxtmi.com/caselaws?id=296747 The petition seeking treaty benefits was dismissed as the applicant was not deemed a resident of the USA under the Double Taxation Avoidance Agreement, thus ineligible for benefits. The presence of a permanent establishment in India was not determined due to non-resident status. The Commissioner clarified that the ruling is binding unless there is a change in law or facts, and additional evidence cannot be accepted post-ruling. The petition was deemed not maintainable as it was filed after the ruling was pronounced, emphasizing the importance of addressing discrepancies through proper legal channels. en-us Mon, 22 Jan 2007 00:00:00 +0530 Thu, 05 Aug 2021 17:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296747 The petition seeking treaty benefits was dismissed as the applicant was not deemed a resident of the USA under the Double Taxation Avoidance Agreement, thus ineligible for benefits. The presence of a permanent establishment in India was not determined due to non-resident status. The Commissioner clarified that the ruling is binding unless there is a change in law or facts, and additional evidence cannot be accepted post-ruling. The petition was deemed not maintainable as it was filed after the ruling was pronounced, emphasizing the importance of addressing discrepancies through proper legal channels. Case-Laws Income Tax Mon, 22 Jan 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296747