https://www.taxtmi.com/caselaws?id=415931 An unexplained investment in immovable property in India made by a UAE tax resident was treated as an application of funds, not income arising from Indian economic activity. On that basis, Article 22 of the India-UAE tax treaty allocated taxing rights to the residence State, while India was neither the residence State nor the source State for the amount. Article 23(1) on capital was held inapplicable because the dispute concerned unexplained investment rather than taxation of capital. The related interest component was also unsustainable because it was not established on the record and had been assessed only tentatively. en-us Tue, 23 Nov 2021 00:00:00 +0530 Fri, 17 Dec 2021 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415931 An unexplained investment in immovable property in India made by a UAE tax resident was treated as an application of funds, not income arising from Indian economic activity. On that basis, Article 22 of the India-UAE tax treaty allocated taxing rights to the residence State, while India was neither the residence State nor the source State for the amount. Article 23(1) on capital was held inapplicable because the dispute concerned unexplained investment rather than taxation of capital. The related interest component was also unsustainable because it was not established on the record and had been assessed only tentatively. Case-Laws Income Tax Tue, 23 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415931