https://www.taxtmi.com/caselaws?id=415951 Treaty exemption under Article 22 of the India-U.S. Double Tax Avoidance Agreement requires compliance with the Tax Residency Certificate condition in Section 90(4) of the Income-tax Act. Although Article 22 exempts qualifying teachers and professors, a non-resident claiming this benefit must obtain a residence certificate from the relevant foreign country. Absence of a United States Tax Residency Certificate prevents satisfaction of this mandatory statutory precondition, so the Article 22 exemption cannot be claimed. en-us Tue, 14 Dec 2021 00:00:00 +0530 Fri, 17 Dec 2021 08:54:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415951 Treaty exemption under Article 22 of the India-U.S. Double Tax Avoidance Agreement requires compliance with the Tax Residency Certificate condition in Section 90(4) of the Income-tax Act. Although Article 22 exempts qualifying teachers and professors, a non-resident claiming this benefit must obtain a residence certificate from the relevant foreign country. Absence of a United States Tax Residency Certificate prevents satisfaction of this mandatory statutory precondition, so the Article 22 exemption cannot be claimed. Case-Laws Income Tax Tue, 14 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415951